Taxation of other income: resident-state taxation subject to permanent establishment connection and source-based gambling taxation. Items of income of a resident not covered by earlier articles are taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case Article 7 or Article 14 applies; income from lotteries, betting and other gambling sourced in the other State may be taxed by that 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: resident-state taxation subject to permanent establishment connection and source-based gambling taxation.
Items of income of a resident not covered by earlier articles are taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case Article 7 or Article 14 applies; income from lotteries, betting and other gambling sourced in the other State may be taxed by that State.
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