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of <h1>Taxation of Dividends: 5% Cap for Major Shareholders, 15% for Others, Over 365 Days, Section Specifics Apply</h1> Dividends paid by a company in one Contracting State to a resident of the other may be taxed in the recipient's State. However, they may also be taxed in the payer's State, with a cap of 5% if the recipient is a company holding at least 25% of the payer's capital, or 15% in other cases. Ownership conditions must be met over a 365-day period. The term 'dividends' includes income from shares and similar rights. These provisions do not apply if the dividends are connected to a permanent establishment or fixed base in the payer's State.
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