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of <h1>Taxation Rules for Cross-Border Dividends: 7.5% or 10% Rate Cap Based on Shareholding, Permanent Establishment Exception</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. Additionally, these dividends can be taxed in the State of the company's residence, but if the recipient is a resident of the other State, the tax is limited to 7.5% if the recipient company holds at least 25% of the shares, or 10% in other cases. The term 'dividends' includes income from shares and similar rights. These provisions do not apply if the recipient has a permanent establishment in the company's State. A State cannot tax dividends paid by a resident company to another State unless connected to a permanent establishment.
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