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of <h1>Article 10 of DTAA Limits Dividend Tax to 10% for Beneficial Owners in Recipient's State; Exceptions Apply</h1> Article 10 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses the taxation of dividends. Dividends paid by a company resident in one state to a resident of the other state may be taxed in the recipient's state. However, they may also be taxed in the state where the company is resident, but this tax should not exceed 10% if the beneficial owner is taxed in the other state. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the dividends are linked to a permanent establishment or fixed base in the paying company's state.
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