Taxation of other income limited to residence, with permanent establishment and gambling exceptions applying accordingly. Other income of a resident not covered elsewhere in the Agreement is taxable only in the resident State, except where the income is effectively connected with a permanent establishment or fixed base in the other State, in which case the provisions on business profits or independent personal services apply; income from lotteries, gambling and similar games sourced in the other State may be taxed by that 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 limited to residence, with permanent establishment and gambling exceptions applying accordingly.
Other income of a resident not covered elsewhere in the Agreement is taxable only in the resident State, except where the income is effectively connected with a permanent establishment or fixed base in the other State, in which case the provisions on business profits or independent personal services apply; income from lotteries, gambling and similar games sourced in the other State may be taxed by that State.
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