Dividends withholding limits restrict source-state taxation; preferential lower rate for substantial shareholders, standard treaty rate otherwise. Dividends may be taxed in the recipient's State but the source State may also tax them subject to treaty withholding limits: a reduced limit for substantial corporate shareholders and a higher limit otherwise. 'Dividends' includes income from shares and corporate rights treated as distributions. If the recipient's holding is effectively connected to a permanent establishment or fixed base in the source State, provisions on business profits or independent personal services apply instead. The source State may not tax dividends paid to non-residents or tax undistributed profits of a resident company.
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 withholding limits restrict source-state taxation; preferential lower rate for substantial shareholders, standard treaty rate otherwise.
Dividends may be taxed in the recipient's State but the source State may also tax them subject to treaty withholding limits: a reduced limit for substantial corporate shareholders and a higher limit otherwise. "Dividends" includes income from shares and corporate rights treated as distributions. If the recipient's holding is effectively connected to a permanent establishment or fixed base in the source State, provisions on business profits or independent personal services apply instead. The source State may not tax dividends paid to non-residents or tax undistributed profits of a resident company.
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