https://www.taxtmi.com/acts?id=23471 Dividends paid by a resident company of one Contracting State to a resident of the other State may be taxed in the recipient's State, while the source State may also tax those dividends subject to a ceiling where the beneficial owner is resident in the other State. The definition of dividends includes income from shares and similar profit-participating rights. The source-state limitation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules apply. en-us Tue, 17 Jan 2017 10:04:02 +0530 Thu, 14 Nov 2024 16:47:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=23471 Dividends paid by a resident company of one Contracting State to a resident of the other State may be taxed in the recipient's State, while the source State may also tax those dividends subject to a ceiling where the beneficial owner is resident in the other State. The definition of dividends includes income from shares and similar profit-participating rights. The source-state limitation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules apply. Act-Rules DTAA Tue, 17 Jan 2017 10:04:02 +0530 https://www.taxtmi.com/acts?id=23471