https://www.taxtmi.com/acts?id=15060 Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such dividends but withholding is capped where the beneficial owner is a qualifying shareholder (5% if a company holding at least ten percent) or otherwise (10%). The Article defines dividends to include income from shares and equivalent corporate rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the provisions on business profits or independent personal services govern; the source State may not tax undistributed profits. en-us Tue, 30 Aug 2011 14:24:10 +0530 Thu, 28 Nov 2024 12:59:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15060 Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such dividends but withholding is capped where the beneficial owner is a qualifying shareholder (5% if a company holding at least ten percent) or otherwise (10%). The Article defines dividends to include income from shares and equivalent corporate rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the provisions on business profits or independent personal services govern; the source State may not tax undistributed profits. Act-Rules DTAA Tue, 30 Aug 2011 14:24:10 +0530 https://www.taxtmi.com/acts?id=15060