TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Cross-Border Dividend Taxation: Limits on Tax Rates for Beneficial Owners Under Specific Ownership Conditions</h1> Dividends paid by a company in one Contracting State to a resident of the other may be taxed in the recipient's State. However, the State where the company resides may also tax these dividends, with limits: 5% for beneficial owners owning at least 10% of shares, and 10% otherwise. 'Dividends' include income from shares and similar rights. These provisions don't apply if the beneficial owner operates a business or provides services in the company's State through a permanent establishment or fixed base. A State cannot tax dividends or undistributed profits from a company in the other State unless connected to a permanent establishment or fixed base.
TaxTMI 
