Dividend taxation caps limit source-state withholding under the treaty, with exceptions for permanent establishments and fixed bases Dividends paid by a company resident in one Contracting State may be taxed in the recipient's State, but the State of the paying company may tax such dividends subject to specified caps when the recipient is the beneficial owner; Malta's tax on dividends to an Indian beneficial owner is limited to tax chargeable on the profits out of which dividends are paid. 'Dividends' is defined to include various share-derived incomes and analogous corporate rights. The withholding limitations do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case provisions on business profits or independent personal services apply.