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of <h1>Taxation on Dividends: Article 10 of DTAA Caps Tax Rate at 15% for Beneficial Owners, Defines 'Dividends' Broadly.</h1> Article 10 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of dividends. Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's state. However, they may also be taxed in the company's resident state, with a maximum tax rate of 15% if the recipient is the beneficial owner. The definition of 'dividends' includes income from shares and similar rights. Exceptions apply if the beneficial owner conducts business through a permanent establishment in the company's resident state. Additionally, a state cannot tax dividends paid by a resident company unless paid to its own residents or connected to a permanent establishment.
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