https://www.taxtmi.com/acts?id=34174 Article 10 governs taxation of dividends: the recipient's state may tax dividends, while the source state may also tax them subject to a treaty limit when the beneficial owner is resident in the other Party. Dividends are defined to include income from shares and equivalent corporate rights. Preferential treatment is excluded where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state; in such cases, Articles on business profits or independent personal services apply. Treaty benefits are denied where share creation or assignment was primarily to obtain treaty relief. en-us Fri, 28 Dec 2018 16:39:03 +0530 Thu, 21 Nov 2024 10:47:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=34174 Article 10 governs taxation of dividends: the recipient's state may tax dividends, while the source state may also tax them subject to a treaty limit when the beneficial owner is resident in the other Party. Dividends are defined to include income from shares and equivalent corporate rights. Preferential treatment is excluded where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state; in such cases, Articles on business profits or independent personal services apply. Treaty benefits are denied where share creation or assignment was primarily to obtain treaty relief. Act-Rules DTAA Fri, 28 Dec 2018 16:39:03 +0530 https://www.taxtmi.com/acts?id=34174