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of <h1>Tax on Dividends: Recipient's State May Tax, Cap at 15% for Companies Holding 25% Shares, 25% Otherwise.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State. They may also be taxed in the payer's State, but if the recipient is the beneficial owner, the tax is capped at 15% if the owner is a company holding at least 25% of shares, and 25% in other cases. 'Dividends' include income from shares and similar rights. Provisions do not apply if the recipient has a business in the payer's State connected to the dividends. A State cannot tax dividends paid to non-residents unless connected to a permanent establishment.
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