Dividend withholding limits capped, with permanent establishment connection shifting taxation to business-source rules and Singapore exemption preserved. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, but the distributing State may also tax them subject to withholding caps of 10% where the beneficial owner is a company with at least 25% ownership and 15% in other cases, without affecting company-level taxation. Singapore exempts dividends to the other State from any additional dividend tax while it does not impose dividend tax beyond corporate profit tax. The withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State.