Taxation of other income: residence State taxed unless effectively connected with a permanent establishment or from gambling. Article 23 allocates primary taxing rights over other income to the resident State for items not dealt with in preceding Articles, except where such income (other than certain immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-in which case the rules on business profits or independent personal services apply-and except that income from lotteries, games, races and other gambling or betting may be taxed in the source State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of other income: residence State taxed unless effectively connected with a permanent establishment or from gambling.
Article 23 allocates primary taxing rights over other income to the resident State for items not dealt with in preceding Articles, except where such income (other than certain immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-in which case the rules on business profits or independent personal services apply-and except that income from lotteries, games, races and other gambling or betting may be taxed in the source State.
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