Dividend withholding limits constrain source-state tax on dividends, with reduced rates for substantial corporate holdings and exceptions for PE-linked income. Article 10 allocates dividend taxing rights: residence states may tax dividends received by residents, while source states may also tax dividends paid by resident companies subject to limited source taxation where the beneficial owner qualifies for reduced rates; these limitations do not affect corporate profit taxation. Exceptions apply where dividends are effectively connected to a permanent establishment or fixed base in the source state, in which case business profits or independent services provisions govern; the Article restricts source-state taxation of dividends and undistributed profits in specified cross-border scenarios and defines 'dividends' to include various equity-like profit participations.