Taxation of other income: residence-based taxation, with exceptions for permanent establishment connections and gambling source rules. Income not dealt with elsewhere in the treaty is taxable only in the resident State, subject to two exceptions: income (other than immovable property) effectively connected with a permanent establishment or fixed base in the other State is taxed under business profits or independent services rules; and income from lotteries, gambling and similar games sourced in the other State is taxable 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: residence-based taxation, with exceptions for permanent establishment connections and gambling source rules.
Income not dealt with elsewhere in the treaty is taxable only in the resident State, subject to two exceptions: income (other than immovable property) effectively connected with a permanent establishment or fixed base in the other State is taxed under business profits or independent services rules; and income from lotteries, gambling and similar games sourced in the other State is taxable in that source State.
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