Dividends withholding limits restrict source-state taxation of cross-border dividends, subject to beneficial ownership and permanent establishment connection. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax them subject to withholding limits where the recipient is the beneficial owner; the competent authorities will settle application. The definition of dividends covers income from shares and similar profit-participating rights. The withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business or independent personal service rules govern.
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.
Dividends withholding limits restrict source-state taxation of cross-border dividends, subject to beneficial ownership and permanent establishment connection.
Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax them subject to withholding limits where the recipient is the beneficial owner; the competent authorities will settle application. The definition of dividends covers income from shares and similar profit-participating rights. The withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business or independent personal service rules govern.
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