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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