https://www.taxtmi.com/acts?id=45318 Taxation of cross border dividends permits taxation in the recipient's State while allowing the payer's State to tax dividends subject to limits when the recipient is the beneficial owner. A reduced withholding rate applies where a corporate beneficial owner meets ownership and continuous holding period requirements (with certain reorganisations disregarded); otherwise a higher rate applies. Dividends include income from shares and equivalent rights, and the Article excludes application where the holding is effectively connected with a permanent establishment or fixed base, in which case business profits or independent services rules apply. en-us Fri, 18 Oct 2024 11:55:04 +0530 Fri, 18 Oct 2024 11:55:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45318 Taxation of cross border dividends permits taxation in the recipient's State while allowing the payer's State to tax dividends subject to limits when the recipient is the beneficial owner. A reduced withholding rate applies where a corporate beneficial owner meets ownership and continuous holding period requirements (with certain reorganisations disregarded); otherwise a higher rate applies. Dividends include income from shares and equivalent rights, and the Article excludes application where the holding is effectively connected with a permanent establishment or fixed base, in which case business profits or independent services rules apply. Act-Rules DTAA Fri, 18 Oct 2024 11:55:04 +0530 https://www.taxtmi.com/acts?id=45318