Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Dividends Taxed in Both States; 10% Cap if Beneficial Owner Without Business in Payer's State.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's State. However, they may also be taxed in the payer's State, with a cap of 10% if the recipient is the beneficial owner. The term 'dividends' includes income from shares and similar rights. The provisions do not apply if the beneficial owner has a business or fixed base in the payer's State connected to the dividends. A Contracting State cannot tax dividends or undistributed profits of a company from the other State, unless connected to a permanent establishment or fixed base in that State.
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