https://www.taxtmi.com/acts?id=5905 Dividends paid by a resident company of one Contracting State to a resident of the other are exempt from taxation in the source state; "dividends" encompass income from shares and analogous corporate rights or any distribution treated as a dividend under the company's residence-state law. The exemption is inapplicable where the recipient carries on business in the source state through a permanent establishment or fixed base and the holding is effectively connected with that establishment, in which case the provisions governing business profits or independent personal services apply. The source state may not tax dividends to non-residents or tax undistributed profits of a resident company arising in the other state. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 10:58:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5905 Dividends paid by a resident company of one Contracting State to a resident of the other are exempt from taxation in the source state; "dividends" encompass income from shares and analogous corporate rights or any distribution treated as a dividend under the company's residence-state law. The exemption is inapplicable where the recipient carries on business in the source state through a permanent establishment or fixed base and the holding is effectively connected with that establishment, in which case the provisions governing business profits or independent personal services apply. The source state may not tax dividends to non-residents or 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=5905