https://www.taxtmi.com/acts?id=41708 Dividends paid by a company resident of one Contracting State to a resident of the other may be taxed in the recipient's State, while the source State may also tax them but with a withholding limitation where the beneficial owner is resident of the other State; this does not affect taxation of the company's profits. The limitation and residence rule do 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 the provisions on business profits or independent personal services apply, and the source State may not tax dividends or undistributed profits except in the specified circumstances. en-us Fri, 05 May 2023 16:33:04 +0530 Fri, 08 Nov 2024 14:46:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=41708 Dividends paid by a company resident of one Contracting State to a resident of the other may be taxed in the recipient's State, while the source State may also tax them but with a withholding limitation where the beneficial owner is resident of the other State; this does not affect taxation of the company's profits. The limitation and residence rule do 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 the provisions on business profits or independent personal services apply, and the source State may not tax dividends or undistributed profits except in the specified circumstances. Act-Rules DTAA Fri, 05 May 2023 16:33:04 +0530 https://www.taxtmi.com/acts?id=41708