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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Cross-Border Dividend Taxation: Limits and Conditions on Taxation by Resident and Recipient States Under Treaty Rules</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. However, the State where the company is resident may also tax these dividends, but not exceeding 10% of the gross amount if the recipient is the beneficial owner. The term 'dividends' refers to income from shares or similar rights. The provisions do not apply if the beneficial owner conducts business through a permanent establishment in the other State. Additionally, a State cannot tax dividends paid by a company resident in another State unless the dividends are connected to a permanent establishment or fixed base in that State.
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