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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Treaty limits withholding on cross-border dividends: 5% for =25% corporate owners, 10% otherwise; exemptions apply</h1> Dividends paid by a company resident in one Contracting State to a resident of the other State may be taxed in the recipient's State, and may also be taxed in the State where the payer is resident subject to a withholding cap: 5% of gross dividends if the beneficial owner is a company holding at least 25% of shares, and 10% otherwise. Dividends paid to the other State, its political subdivisions or local authorities are taxable only in the recipient State. 'Dividends' covers income from shares and similar participations. The reduced rates do not apply where the beneficial owner's holding is effectively connected to a permanent establishment or fixed base in the payer's State, in which case business income rules apply. The source State may not tax dividends except as provided, nor tax undistributed profits.
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