Dividend withholding limits restrict source-state taxation, preserving residence-state rights and exceptions for permanent establishments. Dividends under the Qatar DTAA may be taxed in the recipient's State, while the source State may also tax them subject to reduced withholding for a resident beneficial owner; caps apply differently for qualifying corporate shareholders and other recipients. Dividends to the other Contracting State or its political subdivisions are taxable only in that State. The withholding rules do not bind where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services govern, and the source State cannot otherwise tax such dividends or undistributed profits beyond treaty provisions.