Dividend taxation: source-state withholding limited for beneficial owners, with carve-outs for PE and fixed-base connections. Taxing rights assign initial taxation of dividends to the recipient's residence, while the source state may tax dividends paid by a resident company but with withholding limits-10% for a corporate beneficial owner holding at least ten percent, 15% otherwise. 'Dividends' covers income from shares and similar profit-participating rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state; in such cases business profits or independent services rules govern. Source states also are restricted from taxing dividends or undistributed profits except as specified.
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 for beneficial owners, with carve-outs for PE and fixed-base connections.
Taxing rights assign initial taxation of dividends to the recipient's residence, while the source state may tax dividends paid by a resident company but with withholding limits-10% for a corporate beneficial owner holding at least ten percent, 15% otherwise. "Dividends" covers income from shares and similar profit-participating rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state; in such cases business profits or independent services rules govern. Source states also are restricted from taxing dividends or undistributed profits except as specified.
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