Introducing the βIn Favour Ofβ filter in Case Laws.
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Introducing the βIn Favour Ofβ filter in Case Laws.
Try it now in Case Laws β


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<h1>Dividends Taxed in Recipient's State; Capped at 15% or 20% Based on Ownership and Activity.</h1> Dividends paid by a company in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. They may also be taxed in the state where the paying company is based, but the tax rate is capped at 15% if the recipient company owns at least 10% of the voting shares and the paying company is engaged in industrial activities. In other cases, the cap is 20%. The term 'dividends' includes income from shares and similar rights. These provisions do not apply if the dividends are connected to a permanent establishment or fixed base in the paying company's state.