Other income: generally taxable only in the resident state, except if effectively connected to a permanent establishment or fixed base. Article 22 provides that other income of a resident is generally taxable only in the state of residence, except where the resident carries on business ... Summary
Other income: generally taxable only in the resident state, except if effectively connected to a permanent establishment or fixed base.
Article 22 provides that other income of a resident is generally taxable only in the state of residence, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other state and the income is effectively connected with that permanent establishment or fixed base; in such cases the income is governed by the rules applicable to business profits or independent personal services.
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