Taxation of unspecified income: residence state taxed, source state may tax if derived there, PE connection exception applies. Income not expressly mentioned in other Articles is taxable only in the resident Contracting State, but income derived from sources in the other ... Summary
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Taxation of unspecified income: residence state taxed, source state may tax if derived there, PE connection exception applies.
Income not expressly mentioned in other Articles is taxable only in the resident Contracting State, but income derived from sources in the other Contracting State may also be taxed there; however, income effectively connected with a permanent establishment or fixed base in the other State is governed by Article 7 or Article 14 rather than the residence-only rule.
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TaxTMI 
TaxTMI 
