https://www.taxtmi.com/acts?id=44881 Dividends paid across Contracting States are taxable in the recipient's State, while the payer's State may also tax such dividends subject to a treaty limit when the recipient is the beneficial owner. The treaty excludes the source-state limit where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer State, in which case Articles 7 or 14 apply. The treaty also restricts a State from taxing dividends of its resident company derived from the other State except for dividends paid to its own residents or where an effective connection exists, and bars taxation of undistributed profits on that basis. en-us Wed, 16 Oct 2024 16:29:32 +0530 Tue, 22 Oct 2024 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44881 Dividends paid across Contracting States are taxable in the recipient's State, while the payer's State may also tax such dividends subject to a treaty limit when the recipient is the beneficial owner. The treaty excludes the source-state limit where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer State, in which case Articles 7 or 14 apply. The treaty also restricts a State from taxing dividends of its resident company derived from the other State except for dividends paid to its own residents or where an effective connection exists, and bars taxation of undistributed profits on that basis. Act-Rules DTAA Wed, 16 Oct 2024 16:29:32 +0530 https://www.taxtmi.com/acts?id=44881