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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Tax on Cross-Border Dividends Capped at 10% for Beneficial Owners Under Specific Conditions; Exemptions for Permanent Establishments Apply.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in both States. However, if the recipient is the beneficial owner, the tax in the company's resident State is capped at 10% of the gross dividend amount. The definition of 'dividends' includes various forms of 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, in which case other articles apply. A company resident in one State cannot be taxed by the other State on undistributed profits unless connected to a permanent establishment.
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