Dividend taxation limits permit source state withholding but cap tax when recipient is the beneficial owner. Dividends under the Spain DTAA may be taxed by the recipient's State, while the source State may also tax them but must limit withholding to 15 per cent where the recipient is the beneficial owner; this does not affect company taxation on profits. The Article defines dividends to include income from shares and similar corporate rights (not debt-claims) and excludes the withholding cap where dividends are effectively connected to a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services apply.