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of <h1>Taxation Rules on Cross-Border Dividends: Rates, Ownership, and Permanent Establishment Criteria Explained Under Tax Treaty Section</h1> Dividends paid by a company in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. Additionally, they may be taxed in the state where the company resides, with limits: 15% or 10% if the recipient company owns at least 25% of the payer's capital for two years. 'Dividends' include various profit-sharing incomes. These provisions don't apply if the dividend recipient has a permanent establishment in the payer's state. A state cannot tax dividends paid by a foreign company unless linked to a local establishment.
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