Dividends taxation limited to source jurisdiction; recipient's state generally lacks taxing right over such dividends. Article 8 allocates dividend taxation to the territory where the distributing company is resident: dividends paid by a company resident of one Contracting State to a resident of the other may be taxed only in the State of residence of the paying company, limiting the recipient State's taxing rights under the Agreement.
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 taxation limited to source jurisdiction; recipient's state generally lacks taxing right over such dividends.
Article 8 allocates dividend taxation to the territory where the distributing company is resident: dividends paid by a company resident of one Contracting State to a resident of the other may be taxed only in the State of residence of the paying company, limiting the recipient State's taxing rights under the Agreement.
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