https://www.taxtmi.com/acts?id=4222 Article 10 allows dividend taxation in the recipient's State while permitting source State taxation of dividends paid by resident companies subject to a reduced withholding where the beneficial owner is resident in the other Contracting State; dividends include income from shares and similar profit-participating corporate rights. Where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, the provisions of business or independent personal services taxation apply instead, and the treaty limits source State taxation of dividends and corporate undistributed profits derived from the other State. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 04 Nov 2024 14:54:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4222 Article 10 allows dividend taxation in the recipient's State while permitting source State taxation of dividends paid by resident companies subject to a reduced withholding where the beneficial owner is resident in the other Contracting State; dividends include income from shares and similar profit-participating corporate rights. Where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, the provisions of business or independent personal services taxation apply instead, and the treaty limits source State taxation of dividends and corporate undistributed profits derived from the other State. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4222