Dividends may be taxed in source state but are limited when the beneficial owner is resident elsewhere under the treaty. Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State, while the source State may also tax them but is limited by a treaty cap where the beneficial owner is resident of the other State; this does not affect company-level taxation. The Article defines dividends to include income from shares and equivalent rights and excludes treaty relief where the holding is effectively connected with a permanent establishment or fixed base, in which case rules on business profits or independent personal services apply.