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 ... Summary
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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