Other income allocation: residence generally taxes miscellaneous income, subject to permanent establishment connection allowing source taxation. Article 22 provides that miscellaneous items of a resident's income not covered by other Articles are generally taxable only in the State of residence. That rule is subject to exception where such income is effectively connected with a permanent establishment or fixed base in the other State, in which case the provisions on business profits or independent personal services apply, and it preserves the source State's ability to tax resident income arising in its territory in specified circumstances.
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 allocation: residence generally taxes miscellaneous income, subject to permanent establishment connection allowing source taxation.
Article 22 provides that miscellaneous items of a resident's income not covered by other Articles are generally taxable only in the State of residence. That rule is subject to exception where such income is effectively connected with a permanent establishment or fixed base in the other State, in which case the provisions on business profits or independent personal services apply, and it preserves the source State's ability to tax resident income arising in its territory in specified circumstances.
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