Taxation of other income: residence-based rule with exceptions for PE connections and source-based gambling income. Article 22 provides that items of income of a resident not dealt with elsewhere are taxable only in the resident's territory, subject to two exceptions: income effectively connected with a permanent establishment or fixed base in the other territory is governed by the provisions on business profits or independent personal services; and income from lotteries, gambling and similar games sourced in the other territory may be taxed in that territory.
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-based rule with exceptions for PE connections and source-based gambling income.
Article 22 provides that items of income of a resident not dealt with elsewhere are taxable only in the resident's territory, subject to two exceptions: income effectively connected with a permanent establishment or fixed base in the other territory is governed by the provisions on business profits or independent personal services; and income from lotteries, gambling and similar games sourced in the other territory may be taxed in that territory.
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