Taxation of dividends: source state may tax payments but limits apply for beneficial owners; PE-related exceptions govern. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax them subject to a treaty limitation where the recipient is the beneficial owner. The Article defines dividends as income from shares and similar non-debt corporate rights. Treaty limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, and the source State may not tax undistributed profits of the 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.
Taxation of dividends: source state may tax payments but limits apply for beneficial owners; PE-related exceptions govern.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax them subject to a treaty limitation where the recipient is the beneficial owner. The Article defines dividends as income from shares and similar non-debt corporate rights. Treaty limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, and the source State may not tax undistributed profits of the company.
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