Taxation of Other Income: primary taxation in resident State, except income effectively connected to a permanent establishment. Items of income of a resident not dealt with in other Articles are taxable only in the resident State, but where the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, Articles 7 or 14 apply; additionally, such income arising in the other State may also be taxed there under a residual taxing power.
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Provisions expressly mentioned in the judgment/order text.
Taxation of Other Income: primary taxation in resident State, except income effectively connected to a permanent establishment.
Items of income of a resident not dealt with in other Articles are taxable only in the resident State, but where the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, Articles 7 or 14 apply; additionally, such income arising in the other State may also be taxed there under a residual taxing power.
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