Dividend withholding limits protect beneficial owners, subject to permanent establishment attribution and residence taxation rules. Dividends may be taxed in the recipient's State and also in the State of the company paying them, but where the beneficial owner is taxed in the recipient State the treaty limits source-state withholding to a capped rate without affecting taxation of the distributing company's profits. The treaty defines dividends to include income from shares and analogous participating corporate rights. The withholding limit does not apply to dividends attributable to a permanent establishment or fixed base in the payer-State, in which case rules for business profits or independent personal services govern; the payer-State is generally barred from taxing dividends or undistributed profits except in specified resident or effectively connected circumstances.