Dividends withholding limits set for source taxation, subject to beneficial owner, permanent establishment exceptions and anti abuse provision. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State and also in the source State but, if the beneficial owner is resident in the other State, source taxation is capped under specified limitations agreed by competent authorities; this does not affect taxation of the company on profits. The Article defines 'dividends,' excludes application where the holding is effectively connected with a permanent establishment or fixed base (in which case business profits or independent personal services rules apply), protects against taxation of undistributed profits, and denies relief where treaty benefits were a principal purpose of share creation or assignment.