Other income: income not covered by earlier treaty articles may be taxed in the state where it arises. Article 22 provides a residual taxation rule: items of income of a resident of one Contracting State not allocated by preceding treaty provisions may be taxed in the other Contracting State where such income arises.
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: income not covered by earlier treaty articles may be taxed in the state where it arises.
Article 22 provides a residual taxation rule: items of income of a resident of one Contracting State not allocated by preceding treaty provisions may be taxed in the other Contracting State where such income arises.
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