Determining the Beneficial Owner of Dividend Income Compared to Other Items of Income in International Taxation: nihil sub sōle novum1

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Article 10(2) dividends	Article 11(2) interest	Article 12(1) royalties
However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that state, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends; b) 15 per cent of the gross amount of the dividends in all other cases.	However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that state, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest.	Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other state.