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of <h1>Cross-Border Dividend Taxation: 15% Cap for Major Shareholders, 20% for Others; Business Presence Exemption Applies</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. However, they can also be taxed in the State where the paying company is resident, with limits of 15% for companies owning at least 25% of shares, and 20% otherwise. Dividends include income from shares and similar rights. The provisions do not apply if the recipient conducts business through a permanent establishment in the paying company's State. A State cannot tax dividends or undistributed profits from a company resident in the other State unless certain conditions are met.
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