Dividend taxation: source State withholding limited when recipient is beneficial owner; other tax rules may apply. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the recipient is the beneficial owner, tax in the source State shall not exceed 10 per cent of the gross amount; the limit does not affect company taxation. The dividend definition includes income from shares and similar profit-participating corporate rights.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend taxation: source State withholding limited when recipient is beneficial owner; other tax rules may apply.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the recipient is the beneficial owner, tax in the source State shall not exceed 10 per cent of the gross amount; the limit does not affect company taxation. The dividend definition includes income from shares and similar profit-participating corporate rights.
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