Taxation of other income: residence rule with exception where income is effectively connected to permanent establishment or fixed base. Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where such income is effectively connected with a permanent establishment or a fixed base in the other Contracting State; in that event the provisions on business profits or independent personal services apply, and notwithstanding these rules the other State may also tax resident income arising in its territory that is not covered by other Articles.
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 rule with exception where income is effectively connected to permanent establishment or fixed base.
Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where such income is effectively connected with a permanent establishment or a fixed base in the other Contracting State; in that event the provisions on business profits or independent personal services apply, and notwithstanding these rules the other State may also tax resident income arising in its territory that is not covered by other Articles.
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