Other income taxation may be limited to the resident country, except when linked to permanent establishment or gambling taxed at source. Article 22 provides that income of a resident not covered by other Articles is taxable only in the resident State, except where (other than immovable property) the income is effectively connected with a permanent establishment or fixed base in the other State-bringing Articles 7 or 14 into play-and except that income from lotteries, gambling, races and similar games sourced in the other State may be taxed in 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.
Other income taxation may be limited to the resident country, except when linked to permanent establishment or gambling taxed at source.
Article 22 provides that income of a resident not covered by other Articles is taxable only in the resident State, except where (other than immovable property) the income is effectively connected with a permanent establishment or fixed base in the other State-bringing Articles 7 or 14 into play-and except that income from lotteries, gambling, races and similar games sourced in the other State may be taxed in that State.
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