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of <h1>Understanding Article 10 of DTAA: Dividends Taxed in Both States, Capped at 10% for Residents Without Permanent Establishment.</h1> Article 10 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of dividends. Dividends paid by a company in one State to a resident of the other State can be taxed in the recipient's State. However, the State where the company resides may also tax these dividends, but the rate should not exceed 10% if the recipient is a resident of the other State. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the recipient conducts business through a permanent establishment in the company's State. The other State cannot tax dividends unless they are connected to a permanent establishment there.
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