Dividends withholding limits protect cross-border investors with reduced rates for substantial shareholdings and exceptions for permanent establishments. Dividends paid by a resident company of one Contracting State to a resident of the other may be taxed in the recipient's State, though the payer's State may also tax such dividends subject to a withholding cap where the recipient is the beneficial owner-reduced where the beneficial owner holds a qualifying participating interest, higher in other cases. The withholding exceptions apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which event the rules on business profits or independent personal services govern; source States are generally precluded from taxing dividends or undistributed profits except in limited cases.
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.
Dividends withholding limits protect cross-border investors with reduced rates for substantial shareholdings and exceptions for permanent establishments.
Dividends paid by a resident company of one Contracting State to a resident of the other may be taxed in the recipient's State, though the payer's State may also tax such dividends subject to a withholding cap where the recipient is the beneficial owner-reduced where the beneficial owner holds a qualifying participating interest, higher in other cases. The withholding exceptions apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which event the rules on business profits or independent personal services govern; source States are generally precluded from taxing dividends or undistributed profits except in limited cases.
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