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of <h1>Dividends Taxed in Recipient's State; 10% Cap if Beneficial Owner; Exceptions for Permanent Establishments Apply.</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in the recipient's state. These dividends can also be taxed in the company's resident state, but if the recipient is the beneficial owner, the tax cannot exceed 10% of the gross amount. Dividends refer to income from shares or similar rights, excluding debt-claims. Exceptions apply if the recipient has a permanent establishment in the company's resident state. A state cannot tax a company's dividends or undistributed profits if the company's profits originate from the other state, unless specific conditions are met.
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