Taxation of other income: resident state generally taxed exclusively, unless effectively connected to a permanent establishment enabling source-state taxation. Other income of a resident is generally taxable only in the State of residence, serving as a residual allocation for items not covered elsewhere in the treaty. Where 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-yielding right or property is effectively connected with that establishment or base, the provisions on business profits or independent personal services apply, and the source State may tax such income accordingly.
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: resident state generally taxed exclusively, unless effectively connected to a permanent establishment enabling source-state taxation.
Other income of a resident is generally taxable only in the State of residence, serving as a residual allocation for items not covered elsewhere in the treaty. Where 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-yielding right or property is effectively connected with that establishment or base, the provisions on business profits or independent personal services apply, and the source State may tax such income accordingly.
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