Taxation of other income: residence-state taxation generally, but income tied to a permanent establishment may be taxed in the source state. Items of income of a resident not dealt with by other Convention Articles are generally taxable only in the State of residence. Where the recipient ... Summary
Taxation of other income: residence-state taxation generally, but income tied to a permanent establishment may be taxed in the source state.
Items of income of a resident not dealt with by other Convention Articles are generally taxable only in the State of residence. Where the recipient carries on business through a permanent establishment or performs independent services from a fixed base in the other Contracting Party and the income is effectively connected with that establishment or base, the rules on business profits or independent personal services apply. Notwithstanding those rules, income of a resident arising in the other Contracting Party may also be taxed in that other Party.
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