Dividend withholding limitation limits source state tax on cross border dividends where recipient is the beneficial owner. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax such dividends subject to a withholding tax cap where the recipient is the beneficial owner. 'Dividends' covers income from shares and similar profit participating rights. The withholding limitation does not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the provisions on business profits or independent personal services apply.