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<h1>Dividends Tax Capped at 10% for Beneficial Owners; Permanent Establishment Rules Apply for Taxation Exceptions.</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in both states, but the tax in the company's state of residence is capped at 10% if the recipient is the beneficial owner. The term 'dividends' includes income from shares or similar rights. The provisions do not apply if the recipient has a permanent establishment or fixed base in the company's state, in which case other articles apply. A Contracting State cannot tax dividends from a company resident in the other state unless connected to a permanent establishment or fixed base in that state.