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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Taxation of Dividends Under Article 10 of DTAA: Maximum 10% Rate for Beneficial Owners, Exceptions Apply</h1> Article 10 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of dividends. Dividends paid by a company resident in one State to a resident of the other State may be taxed in the recipient's State. However, the State where the company is resident may also tax these dividends, with a maximum tax rate of 10% if the recipient is the beneficial owner. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the dividends are connected to a permanent establishment or fixed base in the paying company's State. Additionally, a State cannot tax dividends paid by a company resident in the other State unless connected to a permanent establishment or fixed base within its jurisdiction.
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