Taxation of other income: generally confined to the resident State, but source State may tax gambling and PE connected income. Other income of a resident is generally taxable only in the resident State; however, if the income is effectively connected with a permanent establishment or fixed base in the other State, Article 7 or Article 14 apply to govern taxation of business profits or independent personal services. Additionally, income from lotteries, gambling, betting, races, card games and similar games derived from sources in the other Contracting 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: generally confined to the resident State, but source State may tax gambling and PE connected income.
Other income of a resident is generally taxable only in the resident State; however, if the income is effectively connected with a permanent establishment or fixed base in the other State, Article 7 or Article 14 apply to govern taxation of business profits or independent personal services. Additionally, income from lotteries, gambling, betting, races, card games and similar games derived from sources in the other Contracting State may be taxed by that source State.
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