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: ... Summary
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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