Taxation of other income: residents taxed in their state, but source state may tax PE connected income and gambling. Article 22 provides that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the State of residence. Exceptions: income (other than immovable property) effectively connected with a permanent establishment or a fixed base in the other State is taxed under Article 7 or Article 14; and income from lotteries, gambling, betting and 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: residents taxed in their state, but source state may tax PE connected income and gambling.
Article 22 provides that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the State of residence. Exceptions: income (other than immovable property) effectively connected with a permanent establishment or a fixed base in the other State is taxed under Article 7 or Article 14; and income from lotteries, gambling, betting and similar games sourced in the other State may be taxed by that source State.
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