Taxation of Other Income: residence-based rule with permanent establishment and gambling source exceptions and fixed base connection. Article 22 provides a residence-based rule for other income, but excludes income (other than immovable property) effectively connected with a permanent establishment or a fixed base performing independent personal services, in which case Articles 7 or 14 apply; it further permits source-state taxation of income from lotteries, games, gambling and betting.
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 permanent establishment and gambling source exceptions and fixed base connection.
Article 22 provides a residence-based rule for other income, but excludes income (other than immovable property) effectively connected with a permanent establishment or a fixed base performing independent personal services, in which case Articles 7 or 14 apply; it further permits source-state taxation of income from lotteries, games, gambling and betting.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
