Dividend withholding limits protect beneficial owners, with exceptions where holdings are effectively connected to a permanent establishment.

Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax them; if the recipient is the beneficial owner the source State's tax is limited to prescribed maximum rates. The term dividends includes income from shares and similar corporate rights. The reduced withholding does not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the rules on business profits or independent personal services apply.

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