https://www.taxtmi.com/acts?id=5965 Article 10 permits both residence-state and source-state taxation of dividends but limits source-state withholding by reference to qualifying corporate beneficial ownership and shareholding conditions and by reference to whether the payer is an industrial undertaking. It defines dividends and sets out categories of industrial undertaking. Where the beneficial owner's holding is effectively connected with a permanent establishment or a fixed base in the source State, the Article's dividend withholding rules do not apply and the rules on business profits or independent personal services govern; the Article also constrains taxation of undistributed profits by the other State. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 18:29:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5965 Article 10 permits both residence-state and source-state taxation of dividends but limits source-state withholding by reference to qualifying corporate beneficial ownership and shareholding conditions and by reference to whether the payer is an industrial undertaking. It defines dividends and sets out categories of industrial undertaking. Where the beneficial owner's holding is effectively connected with a permanent establishment or a fixed base in the source State, the Article's dividend withholding rules do not apply and the rules on business profits or independent personal services govern; the Article also constrains taxation of undistributed profits by the other State. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5965