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Technical Discussion: If recipient of dividends is not the beneficial owner, can the tax treaty between the source state and the beneficial owner’s residence state apply?

 By: Dr. Amar Mehta  -  December 17, 2020

In a case where Company S in Country S pays dividends to Company R in Country R but the beneficial owner of that income (Company B) is tax resident of Country B, would it be possible to apply the concessional withholding tax rate stipulated in paragraph 2 of Art. 10 (Dividends) of the tax treaty between Countries S and B?

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