Dividend withholding tax limits protect cross-border shareholders by capping source-state tax on company distributions to non-residents. Taxation of cross-border dividends allocates primary taxing rights to the recipient's State while allowing limited source-state taxation by the State of residence of the distributing company, capped when the recipient is the beneficial owner and subject to special limiting rules where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State.
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Provisions expressly mentioned in the judgment/order text.
Dividend withholding tax limits protect cross-border shareholders by capping source-state tax on company distributions to non-residents.
Taxation of cross-border dividends allocates primary taxing rights to the recipient's State while allowing limited source-state taxation by the State of residence of the distributing company, capped when the recipient is the beneficial owner and subject to special limiting rules where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State.
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