https://www.taxtmi.com/acts?id=45545 Dividends paid by a company resident of one Contracting State to a resident of the other may be taxed in the recipient's State but may also be taxed in the source State subject to a capped tax where the recipient is the beneficial owner. "Dividends" covers income from shares and similar profit-participating rights. The withholding limit does not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State; in that event, rules for business profits or independent personal services govern. The source State cannot tax such dividends when they derive from the other State except in specified resident or effectively connected cases, nor tax undistributed profits on that basis. en-us Fri, 18 Oct 2024 16:33:59 +0530 Tue, 22 Oct 2024 18:23:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45545 Dividends paid by a company resident of one Contracting State to a resident of the other may be taxed in the recipient's State but may also be taxed in the source State subject to a capped tax where the recipient is the beneficial owner. "Dividends" covers income from shares and similar profit-participating rights. The withholding limit does not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State; in that event, rules for business profits or independent personal services govern. The source State cannot tax such dividends when they derive from the other State except in specified resident or effectively connected cases, nor tax undistributed profits on that basis. Act-Rules DTAA Fri, 18 Oct 2024 16:33:59 +0530 https://www.taxtmi.com/acts?id=45545