https://www.taxtmi.com/acts?id=45350 Article 11 allows taxation of dividends in the recipient's State while permitting the source State to tax dividends from resident companies subject to a capped withholding when the recipient is the beneficial owner. "Dividends" cover income from shares and profit-participating rights. The dividend rules are displaced where the beneficial owner's shareholding is effectively connected with a permanent establishment or fixed base in the source State; in that case rules for business profits or independent personal services apply. The source State is restricted from taxing dividends or undistributed profits beyond these provisions. en-us Fri, 18 Oct 2024 12:21:48 +0530 Fri, 18 Oct 2024 12:21:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45350 Article 11 allows taxation of dividends in the recipient's State while permitting the source State to tax dividends from resident companies subject to a capped withholding when the recipient is the beneficial owner. "Dividends" cover income from shares and profit-participating rights. The dividend rules are displaced where the beneficial owner's shareholding is effectively connected with a permanent establishment or fixed base in the source State; in that case rules for business profits or independent personal services apply. The source State is restricted from taxing dividends or undistributed profits beyond these provisions. Act-Rules DTAA Fri, 18 Oct 2024 12:21:48 +0530 https://www.taxtmi.com/acts?id=45350