https://www.taxtmi.com/acts?id=14999 paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the State of residence of the paying company may also tax such dividends but, where the beneficial owner is resident of the other State, the source-state's tax is limited by treaty. "" includes income from shares and analogous corporate rights. The treaty's reduced taxing rights do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or a fixed base in the payer's State, in which case the rules on business profits or independent personal services govern. The other State may not tax dividends or undistributed profits derived from it except as to residents or effectively connected holdings. en-us Tue, 30 Aug 2011 12:28:40 +0530 Tue, 26 Nov 2024 16:25:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14999 paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the State of residence of the paying company may also tax such dividends but, where the beneficial owner is resident of the other State, the source-state's tax is limited by treaty. "" includes income from shares and analogous corporate rights. The treaty's reduced taxing rights do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or a fixed base in the payer's State, in which case the rules on business profits or independent personal services govern. The other State may not tax dividends or undistributed profits derived from it except as to residents or effectively connected holdings. Act-Rules DTAA Tue, 30 Aug 2011 12:28:40 +0530 https://www.taxtmi.com/acts?id=14999