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of <h1>Tax Rules on Cross-Border Dividends: 10% Tax Cap for 10% Shareholders, 15% Otherwise; Exemptions Apply for Permanent Establishments.</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in the recipient's State. However, they may also be taxed in the payer's State, with a cap of 10% if the recipient company owns at least 10% of the payer's shares, or 15% otherwise. The term 'dividends' includes income from shares or similar rights. These provisions do not apply if the recipient has a business or fixed base in the payer's State connected to the dividends. A Contracting State cannot tax dividends paid by a resident company to another State, unless connected with a permanent establishment.
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