https://www.taxtmi.com/acts?id=4505 Dividends paid cross-border may be taxed in the recipient's State, while the payer State may also tax such dividends subject to a treaty withholding limit when the recipient is the beneficial owner. The Article defines dividends to include income from shares and similar profit participating corporate rights. The reduced withholding does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer State, in which case business profits or independent personal services provisions govern. The payer State may not tax undistributed profits of a resident company arising in the other State. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 08 Nov 2024 15:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4505 Dividends paid cross-border may be taxed in the recipient's State, while the payer State may also tax such dividends subject to a treaty withholding limit when the recipient is the beneficial owner. The Article defines dividends to include income from shares and similar profit participating corporate rights. The reduced withholding does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer State, in which case business profits or independent personal services provisions govern. The payer State may not tax undistributed profits of a resident company arising in the other State. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4505