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of <h1>Taxation Rules for Dividends under Article 10 of DTAA: Beneficial Owners, Rates, and Exceptions Explained</h1> Article 10 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of dividends. Dividends paid by a company in one State to a resident of the other State, who is the beneficial owner, may be taxed in the recipient's State. The State where the company resides may also tax these dividends, but not exceeding 10% of the gross amount if the recipient is the beneficial owner. Exceptions include dividends paid to government entities or financial institutions of the other State. The term 'dividends' encompasses income from shares and similar rights. Specific provisions apply if the dividends are connected to a permanent establishment.
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