Other income: generally taxable in the resident state, but source taxation applies if effectively connected to a permanent establishment. Other income of a resident is taxable only in the State of residence. If the resident carries on business in the other Contracting State through a ... Summary
Other income: generally taxable in the resident state, but source taxation applies if effectively connected to a permanent establishment.
Other income of a resident is taxable only in the State of residence. If the resident carries on business in the other Contracting State through a permanent establishment and the income is effectively connected with that permanent establishment, Article 7 applies. Notwithstanding those rules, income of a resident not dealt with elsewhere in the Agreement and arising in the other State may also be taxed in that other State.
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