https://www.taxtmi.com/acts?id=44819 Article 10 permits the residence State of the beneficial owner to tax dividends and allows the State of the payer's residence to tax those dividends subject to a treaty cap when the recipient is the beneficial owner resident of the other Contracting State. Dividends are defined to include income from shares and similar profit-participating rights. The reduced-rate provisions do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case business or professional income rules apply; the treaty also limits taxation of dividends and undistributed profits by the other State except in specified connected or resident circumstances. en-us Wed, 16 Oct 2024 15:36:54 +0530 Tue, 22 Oct 2024 13:02:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44819 Article 10 permits the residence State of the beneficial owner to tax dividends and allows the State of the payer's residence to tax those dividends subject to a treaty cap when the recipient is the beneficial owner resident of the other Contracting State. Dividends are defined to include income from shares and similar profit-participating rights. The reduced-rate provisions do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case business or professional income rules apply; the treaty also limits taxation of dividends and undistributed profits by the other State except in specified connected or resident circumstances. Act-Rules DTAA Wed, 16 Oct 2024 15:36:54 +0530 https://www.taxtmi.com/acts?id=44819