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of <h1>Double Taxation on Dividends: Beneficial Owners Face 5% to 15% Cap Under Conditions</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in both states. The state where the company resides can tax these dividends, but if the recipient is the beneficial owner, the tax is capped at 5% if the owner is a company holding at least 10% of the capital, and 15% in other cases. 'Dividends' include income from shares and similar rights. These provisions do not apply if the beneficial owner operates a business or provides services in the state where the dividends originate through a permanent establishment or fixed base.
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