Dividend taxation limits govern source withholding with reduced rates for qualifying beneficial owners and effective-connection exceptions. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the company's State of residence may also tax those dividends but subject to mutually agreed limitations on the rate where the beneficial owner is a resident of the other State. The Article defines 'dividends' to include income from shares and similar corporate rights. The withholding limitations do not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the holding is effectively connected, in which case rules for business profits or independent personal services govern.
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.
Dividend taxation limits govern source withholding with reduced rates for qualifying beneficial owners and effective-connection exceptions.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the company's State of residence may also tax those dividends but subject to mutually agreed limitations on the rate where the beneficial owner is a resident of the other State. The Article defines "dividends" to include income from shares and similar corporate rights. The withholding limitations do not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the holding is effectively connected, in which case rules for business profits or independent personal services govern.
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