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of <h1>Article 10 OECD & UN Models: Rules on Dividends Taxation, Limits Source State Rates to 5% or 15%</h1> Article 10 of the OECD and UN Model Tax Conventions addresses the taxation of dividends in international taxation. It allows the state of residence to tax dividends received by its residents from a company in another contracting state. Conversely, the source state can also tax these dividends, but the rate is limited to 5% if the beneficial owner is a company holding at least 25% of the dividend-paying company for a year, or 15% in other cases. Exceptions apply if the beneficial owner operates through a permanent establishment in the source state. The term 'dividends' includes income from various corporate rights.
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