Taxation of other income: resident-state taxation subject to permanent establishment or fixed base exceptions and gambling taxed at source. Article 23 prescribes that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where ... Summary
Taxation of other income: resident-state taxation subject to permanent establishment or fixed base exceptions and gambling taxed at source.
Article 23 prescribes that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where the income (other than immovable property) is effectively connected with a permanent establishment or a fixed base in the other State-in which case rules for business profits or independent personal services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed in that source State.
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