https://www.taxtmi.com/acts?id=45288 Treaty permits both residence and source taxation of dividends but caps source-state withholding when the recipient is the beneficial owner. A lower cap applies where the beneficial owner is a company meeting an ownership threshold and a continuous 365 day holding requirement; a higher cap applies otherwise. The withholding limits do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, where business-connection provisions govern. The treaty defines dividends as income from shares and similar profit-participating corporate rights. en-us Fri, 18 Oct 2024 11:28:41 +0530 Fri, 18 Oct 2024 11:28:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45288 Treaty permits both residence and source taxation of dividends but caps source-state withholding when the recipient is the beneficial owner. A lower cap applies where the beneficial owner is a company meeting an ownership threshold and a continuous 365 day holding requirement; a higher cap applies otherwise. The withholding limits do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, where business-connection provisions govern. The treaty defines dividends as income from shares and similar profit-participating corporate rights. Act-Rules DTAA Fri, 18 Oct 2024 11:28:41 +0530 https://www.taxtmi.com/acts?id=45288