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of <h1>Article 10: Taxation of Dividends in Swiss Double Taxation Agreement Caps Source State Tax at 10%</h1> Article 10 of the Double Taxation Avoidance Agreement between the Swiss Confederation and another contracting state addresses the taxation of dividends. Dividends paid by a company resident in one contracting state to a resident of the other may be taxed in the recipient's state. However, they may also be taxed in the state where the company is resident, with a maximum tax rate of 10% if the recipient is a resident of the other state. These provisions do not apply if the dividend recipient conducts business through a permanent establishment or fixed base in the company's resident state. The article also restricts the other state from taxing dividends unless they are connected to a permanent establishment or fixed base in that state.
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