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of <h1>Tax on Cross-Border Dividends Capped at 15% for Beneficial Owners; Special Rules for Permanent Establishments</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in both States, but the tax in the company's resident State should not exceed 15% if the recipient is the beneficial owner. 'Dividends' include income from shares or similar corporate rights. If the recipient conducts business through a permanent establishment in the company's resident State, the tax provisions change. A State cannot tax dividends paid by a resident company to another State's resident unless connected to a permanent establishment or fixed base in that State, nor tax the company's undistributed profits.
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