https://www.taxtmi.com/acts?id=14966 Dividends paid by a resident company to a resident of the other Contracting State may be taxed in both States, but where the beneficial owner is resident in the other State the source State's tax on those dividends is limited by a withholding ceiling. "Dividends" covers income from shares and similar non debt profit participating rights and corporate rights treated as share income. The withholding limitation is inapplicable where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services apply. A State receiving profits from the other Contracting State may not tax dividends to non residents or undistributed profits except in specified resident or PE connected circumstances. en-us Tue, 30 Aug 2011 12:02:00 +0530 Tue, 26 Nov 2024 14:19:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14966 Dividends paid by a resident company to a resident of the other Contracting State may be taxed in both States, but where the beneficial owner is resident in the other State the source State's tax on those dividends is limited by a withholding ceiling. "Dividends" covers income from shares and similar non debt profit participating rights and corporate rights treated as share income. The withholding limitation is inapplicable where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services apply. A State receiving profits from the other Contracting State may not tax dividends to non residents or undistributed profits except in specified resident or PE connected circumstances. Act-Rules DTAA Tue, 30 Aug 2011 12:02:00 +0530 https://www.taxtmi.com/acts?id=14966