Other income: generally taxable in the resident state, but source taxation applies if effectively connected to a permanent establishment. Other income of a resident is taxable only in the State of residence. If the resident carries on business in the other Contracting State through a permanent establishment and the income is effectively connected with that permanent establishment, Article 7 applies. Notwithstanding those rules, income of a resident not dealt with elsewhere in the Agreement and arising in the other State may also be taxed in that other 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: generally taxable in the resident state, but source taxation applies if effectively connected to a permanent establishment.
Other income of a resident is taxable only in the State of residence. If the resident carries on business in the other Contracting State through a permanent establishment and the income is effectively connected with that permanent establishment, Article 7 applies. Notwithstanding those rules, income of a resident not dealt with elsewhere in the Agreement and arising in the other State may also be taxed in that other State.
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