Taxation of other income: residence-based rule with source state rights where permanent establishment or fixed base connection exists. Article 22 treats items of 'other income' not covered elsewhere as taxable primarily in the recipient's State of residence. If the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income is effectively connected with that establishment or base, Articles 7 or 14 govern taxation. Additionally, the source State retains a residual right to tax other income arising in its 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 source state rights where permanent establishment or fixed base connection exists.
Article 22 treats items of "other income" not covered elsewhere as taxable primarily in the recipient's State of residence. If the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income is effectively connected with that establishment or base, Articles 7 or 14 govern taxation. Additionally, the source State retains a residual right to tax other income arising in its territory.
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