Other income: residence taxation as default, but source taxation applies for PE/fixed base connections and gambling. Other income not dealt with elsewhere is generally taxable only in the resident State. If the recipient 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 establishment or base, the provisions governing business profits or independent personal services apply. Income from lotteries, games, races and other gambling arising in the source 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.
Other income: residence taxation as default, but source taxation applies for PE/fixed base connections and gambling.
Other income not dealt with elsewhere is generally taxable only in the resident State. If the recipient 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 establishment or base, the provisions governing business profits or independent personal services apply. Income from lotteries, games, races and other gambling arising in the source State may be taxed by that source State.
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