https://www.taxtmi.com/acts?id=18906 Article 10 permits taxation of dividends by the recipient's State and also by the State of the distributing company subject to treaty limits; when the beneficial owner resides in the other Contracting State the distributing State's withholding tax is capped or, for Malta, limited to the domestic tax on the profits from which the dividends are paid, while the company's taxation on its profits is preserved. Dividends are broadly defined and the Article excludes application where dividends are effectively connected with a permanent establishment or fixed base, invoking rules on business profits or independent personal services instead. en-us Tue, 12 Aug 2014 13:39:52 +0530 Tue, 26 Nov 2024 18:04:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18906 Article 10 permits taxation of dividends by the recipient's State and also by the State of the distributing company subject to treaty limits; when the beneficial owner resides in the other Contracting State the distributing State's withholding tax is capped or, for Malta, limited to the domestic tax on the profits from which the dividends are paid, while the company's taxation on its profits is preserved. Dividends are broadly defined and the Article excludes application where dividends are effectively connected with a permanent establishment or fixed base, invoking rules on business profits or independent personal services instead. Act-Rules DTAA Tue, 12 Aug 2014 13:39:52 +0530 https://www.taxtmi.com/acts?id=18906