https://www.taxtmi.com/acts?id=44974 The Article allocates taxing rights over dividends: the recipient's State may tax dividends, while the source State may also tax them but subject to a treaty-prescribed maximum withholding rate where the beneficial owner is a resident of the other State. The definition of dividends covers share income and similar profit-participating rights. The preferential withholding rules 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 rules for business profits or independent personal services govern, and the Article prevents taxation of undistributed profits by the other State except in limited connected circumstances. en-us Wed, 16 Oct 2024 17:33:26 +0530 Tue, 22 Oct 2024 11:41:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44974 The Article allocates taxing rights over dividends: the recipient's State may tax dividends, while the source State may also tax them but subject to a treaty-prescribed maximum withholding rate where the beneficial owner is a resident of the other State. The definition of dividends covers share income and similar profit-participating rights. The preferential withholding rules 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 rules for business profits or independent personal services govern, and the Article prevents taxation of undistributed profits by the other State except in limited connected circumstances. Act-Rules DTAA Wed, 16 Oct 2024 17:33:26 +0530 https://www.taxtmi.com/acts?id=44974