Taxation of other income: generally taxable only in resident state, subject to permanent establishment and effective connection exceptions. Income of a resident not covered by earlier Articles is generally taxable only in the resident State, except where the resident 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 permanent establishment or fixed base, in which case rules for business profits or independent personal services apply; notwithstanding these provisions, such income arising in the other State may be taxed in that other State.
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: generally taxable only in resident state, subject to permanent establishment and effective connection exceptions.
Income of a resident not covered by earlier Articles is generally taxable only in the resident State, except where the resident 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 permanent establishment or fixed base, in which case rules for business profits or independent personal services apply; notwithstanding these provisions, such income arising in the other State may be taxed in that other State.
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