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 ... Summary
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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