https://www.taxtmi.com/acts?id=4534 Dividend payments by a company resident in one Contracting State may be taxed in the recipient's State, but the source State may also tax such dividends; when the recipient is the beneficial owner the source State's tax is limited by prescribed rates and the competent authorities shall agree the mode of applying these limitations. The limitation does not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the rules on business profits or independent personal services govern, and the source State may not tax dividends except in specified resident or effectively connected circumstances nor tax undistributed profits. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 18:18:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4534 Dividend payments by a company resident in one Contracting State may be taxed in the recipient's State, but the source State may also tax such dividends; when the recipient is the beneficial owner the source State's tax is limited by prescribed rates and the competent authorities shall agree the mode of applying these limitations. The limitation does not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the rules on business profits or independent personal services govern, and the source State may not tax dividends except in specified resident or effectively connected circumstances nor tax undistributed profits. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4534