Dividend taxation: source state may tax dividends but withholding limited when beneficial owner resides in the other state. Dividends paid cross border may be taxed in the recipient's state, while the source state may also tax them subject to a maximum withholding limit when the beneficial owner is resident in the other Contracting State; company taxation on profits used for dividends remains unaffected. The Article defines dividends to include income from share like rights and certain returns on capital for entities without share capital.
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: source state may tax dividends but withholding limited when beneficial owner resides in the other state.
Dividends paid cross border may be taxed in the recipient's state, while the source state may also tax them subject to a maximum withholding limit when the beneficial owner is resident in the other Contracting State; company taxation on profits used for dividends remains unaffected. The Article defines dividends to include income from share like rights and certain returns on capital for entities without share capital.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
