Taxation of other income: generally taxable only in resident state, but source state may tax if linked to permanent establishment. Article 22 makes residency the primary taxing right for items of income not covered elsewhere in the Treaty, but provides that where a resident carries on ... Summary
Taxation of other income: generally taxable only in resident state, but source state may tax if linked to permanent establishment.
Article 22 makes residency the primary taxing right for items of income not covered elsewhere in the Treaty, but provides that where a 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 presence, the provisions on business profits or independent personal services (Article 7 or Article 14) apply; additionally, the other State retains a residual right to tax such income arising within its territory.
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