Dividend taxation limits: source-state withholding is constrained when the beneficial owner qualifies, with exceptions for permanent establishments. Article 10 permits taxation of dividends in the beneficial owner's State while allowing the payer's State to impose withholding tax subject to reduced ceilings where ownership and continuity conditions are met; competent authorities shall agree on application. 'Dividends' covers income from shares and equivalent corporate rights. Reduced withholding does not apply when the holding is effectively connected to a permanent establishment or fixed base in the payer State, where Articles on business profits or independent services govern. The Article restricts the other State from taxing dividends or undistributed profits except in specified connected circumstances.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend taxation limits: source-state withholding is constrained when the beneficial owner qualifies, with exceptions for permanent establishments.
Article 10 permits taxation of dividends in the beneficial owner's State while allowing the payer's State to impose withholding tax subject to reduced ceilings where ownership and continuity conditions are met; competent authorities shall agree on application. "Dividends" covers income from shares and equivalent corporate rights. Reduced withholding does not apply when the holding is effectively connected to a permanent establishment or fixed base in the payer State, where Articles on business profits or independent services govern. The Article restricts the other State from taxing dividends or undistributed profits except in specified connected circumstances.
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