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of <h1>Cross-Border Dividends Taxed in Recipient's State; Paying State's Tax Capped at 15% Unless Business is Conducted Locally.</h1> Dividends paid by a company in one Contracting State to a resident of another Contracting State may be taxed in the recipient's State. However, the State where the paying company resides can also tax these dividends, but the tax should not exceed 15% if the recipient is a resident of the other State. The term 'dividends' includes income from shares and similar rights, excluding debt-claims. If the recipient conducts business through a permanent establishment in the paying company's State, different tax rules apply. A State cannot tax dividends paid by a company resident in another State unless connected to a permanent establishment within its jurisdiction.
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