https://www.taxtmi.com/acts?id=4968 may be taxed in the recipient's residence but the source State may also tax dividends paid by its resident company; however, when the recipient is the beneficial owner the source tax on such dividends is limited by a prescribed cap. The withholding limits do not affect company taxation on the profits distributed. If the beneficial owner carries on business through a permanent establishment or fixed base in the source State and the holding is effectively connected, taxation is governed by the business profits or independent personal services provisions. A State where a company derives income from another State may not tax dividends paid by that company to nonresidents or impose a tax on undistributed profits, except where dividends are paid to residents or are effectively connected with a permanent establishment or fixed base. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Dec 2024 11:53:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4968 may be taxed in the recipient's residence but the source State may also tax dividends paid by its resident company; however, when the recipient is the beneficial owner the source tax on such dividends is limited by a prescribed cap. The withholding limits do not affect company taxation on the profits distributed. If the beneficial owner carries on business through a permanent establishment or fixed base in the source State and the holding is effectively connected, taxation is governed by the business profits or independent personal services provisions. A State where a company derives income from another State may not tax dividends paid by that company to nonresidents or impose a tax on undistributed profits, except where dividends are paid to residents or are effectively connected with a permanent establishment or fixed base. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4968