Dividend withholding limits: treaty permits source state tax subject to a treaty cap for beneficial owners, with PE exceptions. The treaty permits the State of residence of the recipient to tax dividends while allowing the source State resident company's State to impose a withholding tax on dividends paid to nonresident beneficial owners subject to a treaty withholding cap; competent authorities shall determine the mode of application. Taxation of the distributing company's profits remains unaffected. 'Dividend' is defined to include various profit participating shares and similar rights. If the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, provisions on business profits or independent personal services govern instead, and the source State may only tax dividends in limited circumstances and may not tax undistributed profits.