Dividend taxation: source state tax limited where recipient is beneficial owner, with permanent establishment exceptions applying.

Dividends paid by a resident company of one Contracting State to a resident of the other State may be taxed in the recipient's State, but the payer's State may also tax them subject to a maximum rate where the recipient is the beneficial owner. The Article treats dividends as income from shares and similar rights and excludes the paragraphs' limitations where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, applying business profits or personal services rules instead.

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