Dividends withholding limits: treaty caps source-state taxation for qualified beneficial owners under specified ownership conditions. The Convention allows the source state to tax dividends paid by its resident companies to residents of the other Contracting State but limits that source taxation by capping withholding rates where the beneficial owner meets specified ownership and residency conditions; otherwise a higher capped rate applies. The Article preserves corporate taxation on distributable profits, defines dividends for treaty application, and subjects dividends effectively connected to a permanent establishment to business profits rules. It also contains sectoral rules for pension funds, RICs, REITs, anti abuse measures for expatriated entities, and interaction with Limitation on Benefits provisions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividends withholding limits: treaty caps source-state taxation for qualified beneficial owners under specified ownership conditions.
The Convention allows the source state to tax dividends paid by its resident companies to residents of the other Contracting State but limits that source taxation by capping withholding rates where the beneficial owner meets specified ownership and residency conditions; otherwise a higher capped rate applies. The Article preserves corporate taxation on distributable profits, defines dividends for treaty application, and subjects dividends effectively connected to a permanent establishment to business profits rules. It also contains sectoral rules for pension funds, RICs, REITs, anti abuse measures for expatriated entities, and interaction with Limitation on Benefits provisions.
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