Source of income deemed in treaty aligns domestic sourcing with the State entitled to tax under treaty allocations.

Where income, profits or gains of a resident are taxable in the other Contracting State under the treaty allocation provisions, those items are deemed to be income from sources in that other State for the purposes of that other State's tax law and, for the treaty relief mechanism and the resident State's tax law, are likewise treated as sourced in the State entitled to tax under the treaty.

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