Other income rules: resident-state taxation, but source-state may tax if linked to a permanent establishment or fixed base. Article 22 allocates primary taxing rights for items of income not dealt with elsewhere to the resident Contracting State. An exception allows the source ... Summary
Other income rules: resident-state taxation, but source-state may tax if linked to a permanent establishment or fixed base.
Article 22 allocates primary taxing rights for items of income not dealt with elsewhere to the resident Contracting State. An exception allows the source State to tax such income when it is effectively connected with a permanent establishment or a fixed base through which the resident carries on business or performs independent personal services, in which case the provisions applicable to business profits or independent personal services apply. A substituted paragraph further permits the other Contracting State to tax items of resident income arising there notwithstanding the primary rule.
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