Dividend taxation: source state may impose a withholding cap while residence taxation remains, with PE exceptions applying. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient State, and may also be taxed in the source State of the distributing company subject to a withholding limit on the gross amount. The Article defines dividends to include various corporate profit-participating rights and excludes these rules where the beneficial owner's holding is effectively connected to a permanent establishment in the source State, in which case business profit rules apply; the source State also generally may not tax dividends or undistributed profits derived from the other State except in specified circumstances.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend taxation: source state may impose a withholding cap while residence taxation remains, with PE exceptions applying.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient State, and may also be taxed in the source State of the distributing company subject to a withholding limit on the gross amount. The Article defines dividends to include various corporate profit-participating rights and excludes these rules where the beneficial owner's holding is effectively connected to a permanent establishment in the source State, in which case business profit rules apply; the source State also generally may not tax dividends or undistributed profits derived from the other State except in specified circumstances.
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