Other income taxation: residence-based taxation with exception where income is effectively connected to a permanent establishment, allowing source taxation. Items of income of a resident not addressed by other Articles are generally taxable only in the resident State, except where the income (excluding ... Summary
Other income taxation: residence-based taxation with exception where income is effectively connected to a permanent establishment, allowing source taxation.
Items of income of a resident not addressed by other Articles are generally taxable only in the resident State, except where the income (excluding immovable property income) arises in the other State and is effectively connected with a permanent establishment through which the recipient carries on business; in that case business profits rules apply, and such other income may also be taxed in the source State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 1
Join Channel
TaxTMI 
