https://www.taxtmi.com/acts?id=16858 Taxation of cross-border dividends is shared: dividends paid by a resident company to a resident of the other State may be taxed in the recipient's State and also in the source State subject to a tax ceiling where the recipient is the beneficial owner. The Article defines dividends to include income from shares and similar profit-participating corporate rights. The source-State cap varies by ownership level and does not affect taxation of the company on profits. Where the beneficial owner has a permanent establishment or fixed base in the source State and the holding is effectively connected, rules on business profits or independent personal services govern instead; the source State generally may not tax dividends or undistributed profits unless the recipient is resident there or the holding is effectively connected. en-us Fri, 03 Aug 2012 18:35:12 +0530 Fri, 20 Dec 2024 18:48:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16858 Taxation of cross-border dividends is shared: dividends paid by a resident company to a resident of the other State may be taxed in the recipient's State and also in the source State subject to a tax ceiling where the recipient is the beneficial owner. The Article defines dividends to include income from shares and similar profit-participating corporate rights. The source-State cap varies by ownership level and does not affect taxation of the company on profits. Where the beneficial owner has a permanent establishment or fixed base in the source State and the holding is effectively connected, rules on business profits or independent personal services govern instead; the source State generally may not tax dividends or undistributed profits unless the recipient is resident there or the holding is effectively connected. Act-Rules DTAA Fri, 03 Aug 2012 18:35:12 +0530 https://www.taxtmi.com/acts?id=16858