Dividend taxation: source state may tax dividends but reduced withholding applies when recipient is beneficial owner in other state.

Article 10 allocates taxing rights over dividends: the recipient's State may tax dividends, and the source State may also tax them but must limit withholding where the beneficial owner is a resident of the other State-applying a reduced rate for substantial corporate shareholders and a different reduced rate otherwise. Dividends include income from shares and similar corporate rights. If the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, rules for business profits or independent personal services apply. The source State may not tax dividends on profits from the other State or tax undistributed profits except in specified connected circumstances.

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