Dividend taxation under treaty: source state tax limited while business-connection exceptions apply to effective connections. Dividends paid between residents of the Contracting States may be taxed in the recipient's state, but the source state may also tax them subject to reduced ceilings when the recipient is the beneficial owner. The treaty defines dividends to include income from shares and similar corporate rights. Reduced source taxation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, where rules for business profits or independent personal services then govern. The source state may not tax such dividends or undistributed profits beyond these treaty limits.
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 under treaty: source state tax limited while business-connection exceptions apply to effective connections.
Dividends paid between residents of the Contracting States may be taxed in the recipient's state, but the source state may also tax them subject to reduced ceilings when the recipient is the beneficial owner. The treaty defines dividends to include income from shares and similar corporate rights. Reduced source taxation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, where rules for business profits or independent personal services then govern. The source state may not tax such dividends or undistributed profits beyond these treaty limits.
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