Dividends taxation: source State may tax, residence taxing power limited when beneficial owner resides in other Contracting State. Taxation of dividends permits taxation by the recipient's State of residence while the State where the distributing company is resident may also tax such dividends, subject to limits when the beneficial owner is resident of the other Contracting State. 'Dividends' covers income from shares and analogous corporate rights. Dividend provisions do not apply where the beneficial owner carries on business or independent personal services in the distributing company's State through a permanent establishment or fixed base and the holding is effectively connected with it; then Article provisions on business profits or independent services govern.
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.
Dividends taxation: source State may tax, residence taxing power limited when beneficial owner resides in other Contracting State.
Taxation of dividends permits taxation by the recipient's State of residence while the State where the distributing company is resident may also tax such dividends, subject to limits when the beneficial owner is resident of the other Contracting State. "Dividends" covers income from shares and analogous corporate rights. Dividend provisions do not apply where the beneficial owner carries on business or independent personal services in the distributing company's State through a permanent establishment or fixed base and the holding is effectively connected with it; then Article provisions on business profits or independent services govern.
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