https://www.taxtmi.com/manuals?id=4460 Article 10 allocates dividend taxing rights: residence states may tax dividends received by residents, while source states may also tax dividends paid by resident companies subject to limited source taxation where the beneficial owner qualifies for reduced rates; these limitations do not affect corporate profit taxation. Exceptions apply where dividends are effectively connected to a permanent establishment or fixed base in the source state, in which case business profits or independent services provisions govern; the Article restricts source-state taxation of dividends and undistributed profits in specified cross-border scenarios and defines "dividends" to include various equity-like profit participations. en-us Mon, 05 Feb 2024 18:26:00 +0530 Wed, 14 Feb 2024 17:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4460 Article 10 allocates dividend taxing rights: residence states may tax dividends received by residents, while source states may also tax dividends paid by resident companies subject to limited source taxation where the beneficial owner qualifies for reduced rates; these limitations do not affect corporate profit taxation. Exceptions apply where dividends are effectively connected to a permanent establishment or fixed base in the source state, in which case business profits or independent services provisions govern; the Article restricts source-state taxation of dividends and undistributed profits in specified cross-border scenarios and defines "dividends" to include various equity-like profit participations. Manuals Income Tax Mon, 05 Feb 2024 18:26:00 +0530 https://www.taxtmi.com/manuals?id=4460