Taxation of other income: residency-based taxation generally, with source-state taxation for gambling and PE-connected receipts. Article 22 provides that other income of a resident not dealt with elsewhere in the treaty is taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-bringing it within Article 7 or Article 14-or where income from lotteries, gambling, betting, races, card games, crossword puzzles or similar games sourced in the other State may be taxed by that 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: residency-based taxation generally, with source-state taxation for gambling and PE-connected receipts.
Article 22 provides that other income of a resident not dealt with elsewhere in the treaty is taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-bringing it within Article 7 or Article 14-or where income from lotteries, gambling, betting, races, card games, crossword puzzles or similar games sourced in the other State may be taxed by that source State.
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