Other income taxation: residence generally controls taxability, with permanent establishment and gambling exceptions. Income not expressly allocated by earlier treaty provisions is taxable only in the resident State, excluding income from immovable property. If the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules on business profits or independent personal services apply. Winnings from lotteries, gambling, races, games and similar sources arising 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.
Other income taxation: residence generally controls taxability, with permanent establishment and gambling exceptions.
Income not expressly allocated by earlier treaty provisions is taxable only in the resident State, excluding income from immovable property. If the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules on business profits or independent personal services apply. Winnings from lotteries, gambling, races, games and similar sources arising in the other State may be taxed in that source State.
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