Article 10 - Dividends

Dividends taxation: source state may withhold up to 15% while residence state may tax, with PE connection exceptions.

Dividends may be taxed in the recipient's State of residence and also in the State where the paying company is resident, subject to a withholding tax cap of 15% on the gross amount. 'Dividends' includes income from shares and similar amounts. If the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, Article 7 or Article 14 applies instead. Non-resident recipients' dividends are exempt in the recipient State unless effectively connected with a permanent establishment or fixed base; this exemption does not apply to companies resident in Australia and also resident in India.