Other income taxation under tax treaty: residence-state taxation with permanent establishment and gambling-source exceptions for cross-border cases Taxation of Other Income assigns primary taxation to the resident State for items not dealt with elsewhere, subject to exceptions: income effectively connected with a permanent establishment or fixed base in the source State is taxed under business profits or independent personal services rules, and winnings from lotteries, games, races and other gambling sourced in the other State may be taxed by 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 under tax treaty: residence-state taxation with permanent establishment and gambling-source exceptions for cross-border cases
Taxation of Other Income assigns primary taxation to the resident State for items not dealt with elsewhere, subject to exceptions: income effectively connected with a permanent establishment or fixed base in the source State is taxed under business profits or independent personal services rules, and winnings from lotteries, games, races and other gambling sourced in the other State may be taxed by that source State.
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