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of <h1>Dividends from one state's company to another's resident taxed up to 25%; lower rate if shares exceed 10%.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's state. However, they may also be taxed in the payer's state, with a maximum tax rate of 15% if the recipient company owns at least 10% of the payer's shares, and 25% in other cases. These provisions do not apply if the beneficial owner has a business or fixed base in the payer's state. The term 'dividends' includes income from various corporate rights. States cannot impose additional taxes on dividends or undistributed profits unless connected to a permanent establishment.
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