Taxation of other income: residency principle subject to permanent establishment and source based rules for gambling income. Article 22 provides that items of income of a resident not dealt with elsewhere are taxable only in the resident State, except 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; in such cases Article 7 or Article 14 apply, and income from lotteries, races, gambling and similar sources may be taxed by the source 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: residency principle subject to permanent establishment and source based rules for gambling income.
Article 22 provides that items of income of a resident not dealt with elsewhere are taxable only in the resident State, except 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; in such cases Article 7 or Article 14 apply, and income from lotteries, races, gambling and similar sources may be taxed by the source State.
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