ABC Finance Co is incorporated in State A and carrying on business of providing finance, trading in securities and deriving dividend income from securities both in State A and State B. The company does not have a fixed place of business in State B and all decisions regarding the companys affairs are made in State A by its Board of Directors.

The company is an extensive dealer in all forms of securities. These securities were traded on various exchanges in State B. Explain how the dividend income will be taxed given that State A and State B have a double tax agreement modelled on the OECD Model Treaty.