https://www.taxtmi.com/acts?id=51356 The Convention allows the source state to tax dividends paid by its resident companies to residents of the other Contracting State but limits that source taxation by capping withholding rates where the beneficial owner meets specified ownership and residency conditions; otherwise a higher capped rate applies. The Article preserves corporate taxation on distributable profits, defines dividends for treaty application, and subjects dividends effectively connected to a permanent establishment to business profits rules. It also contains sectoral rules for pension funds, RICs, REITs, anti abuse measures for expatriated entities, and interaction with Limitation on Benefits provisions. en-us Wed, 21 May 2025 15:36:36 +0530 Wed, 21 May 2025 15:36:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51356 The Convention allows the source state to tax dividends paid by its resident companies to residents of the other Contracting State but limits that source taxation by capping withholding rates where the beneficial owner meets specified ownership and residency conditions; otherwise a higher capped rate applies. The Article preserves corporate taxation on distributable profits, defines dividends for treaty application, and subjects dividends effectively connected to a permanent establishment to business profits rules. It also contains sectoral rules for pension funds, RICs, REITs, anti abuse measures for expatriated entities, and interaction with Limitation on Benefits provisions. Act-Rules DTAA Wed, 21 May 2025 15:36:36 +0530 https://www.taxtmi.com/acts?id=51356