https://www.taxtmi.com/acts?id=37641 Article 10 limits source-state taxation of dividends paid to a resident beneficial owner of the other Contracting State by imposing a treaty cap on such taxation while preserving the taxing rights of the recipient State. The article excludes treaty relief where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services apply, and it restricts source States from taxing dividends or undistributed profits derived from the other Contracting State except in those specified circumstances. en-us Thu, 19 Sep 2019 12:13:35 +0530 Tue, 26 Nov 2024 17:51:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37641 Article 10 limits source-state taxation of dividends paid to a resident beneficial owner of the other Contracting State by imposing a treaty cap on such taxation while preserving the taxing rights of the recipient State. The article excludes treaty relief where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services apply, and it restricts source States from taxing dividends or undistributed profits derived from the other Contracting State except in those specified circumstances. Act-Rules DTAA Thu, 19 Sep 2019 12:13:35 +0530 https://www.taxtmi.com/acts?id=37641