Taxation of other income: residents generally taxed in their State, but source may tax gambling and PE connected income. Article 22 provides that income of a resident not dealt with elsewhere in the Convention is generally taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case the rules for business profits or independent personal services apply; income from lotteries, games, races, gambling or betting sourced in the other State may be taxed in 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: residents generally taxed in their State, but source may tax gambling and PE connected income.
Article 22 provides that income of a resident not dealt with elsewhere in the Convention is generally taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case the rules for business profits or independent personal services apply; income from lotteries, games, races, gambling or betting sourced in the other State may be taxed in that source State.
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