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of <h1>Tax Rules for International Dividends: 5% Cap for Major Shareholders, 15% for Others Under Treaty Provisions</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the latter. However, they can also be taxed in the company's resident state, with tax capped at 5% if the beneficial owner is a company holding at least 25% of the capital, and 15% in other cases. These provisions do not apply if the dividends are connected to a permanent establishment or fixed base in the other state. The term 'dividends' includes income from shares and similar rights. States cannot tax dividends paid by a resident company unless they are connected to a permanent establishment or fixed base.
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