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 ... Summary
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.
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