https://www.taxtmi.com/acts?id=4849 paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax such dividends; if the recipient is the beneficial owner, source tax is limited to 10 per cent of the gross amount. The limitation does not affect company taxation on profits. Dividend treatment includes income from shares and similar corporate rights. The reduced source taxation 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 business profits or independent personal services provisions apply, and a State generally may not tax dividends or undistributed profits of a resident company derived from the other Contracting State except in those specified circumstances. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Dec 2024 17:10:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4849 paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax such dividends; if the recipient is the beneficial owner, source tax is limited to 10 per cent of the gross amount. The limitation does not affect company taxation on profits. Dividend treatment includes income from shares and similar corporate rights. The reduced source taxation 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 business profits or independent personal services provisions apply, and a State generally may not tax dividends or undistributed profits of a resident company derived from the other Contracting State except in those specified circumstances. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4849