https://www.taxtmi.com/acts?id=15169 The treaty permits the residence of a dividend recipient to tax dividends but allows the source territory to tax such dividends up to a capped rate when the recipient is the beneficial owner. "" covers income from shares and equivalent corporate rights, excluding debt-claims, and does not affect taxation of the payer's profits. Reduced-source-tax rules do not apply where the beneficial owner's holding is effectively connected to a permanent establishment or fixed base in the source territory; in such cases business or independent services articles govern. The source territory is generally restricted from taxing dividends and undistributed profits derived from the other territory except for resident recipients or effectively connected holdings. en-us Mon, 12 Sep 2011 18:30:40 +0530 Sat, 31 Aug 2024 13:28:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15169 The treaty permits the residence of a dividend recipient to tax dividends but allows the source territory to tax such dividends up to a capped rate when the recipient is the beneficial owner. "" covers income from shares and equivalent corporate rights, excluding debt-claims, and does not affect taxation of the payer's profits. Reduced-source-tax rules do not apply where the beneficial owner's holding is effectively connected to a permanent establishment or fixed base in the source territory; in such cases business or independent services articles govern. The source territory is generally restricted from taxing dividends and undistributed profits derived from the other territory except for resident recipients or effectively connected holdings. Act-Rules DTAA Mon, 12 Sep 2011 18:30:40 +0530 https://www.taxtmi.com/acts?id=15169