https://www.taxtmi.com/acts?id=5065 may be taxed in the recipient's State, but the source State of the paying company may also tax them under its laws subject to a withholding limitation when the recipient is the beneficial owner. "" include income from shares and equivalent profit-participating rights. The limitation is inapplicable if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business income rules apply. A company's State of residence may not tax dividends paid from the other State or tax undistributed profits except where the dividend recipient is a resident of that other State or the holding is effectively connected with a permanent establishment or fixed base there. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 16:43:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5065 may be taxed in the recipient's State, but the source State of the paying company may also tax them under its laws subject to a withholding limitation when the recipient is the beneficial owner. "" include income from shares and equivalent profit-participating rights. The limitation is inapplicable if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business income rules apply. A company's State of residence may not tax dividends paid from the other State or tax undistributed profits except where the dividend recipient is a resident of that other State or the holding is effectively connected with a permanent establishment or fixed base there. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5065