Taxation of other income: treaty permits source state to tax income not covered elsewhere under the convention. Article 22 provides that items of income of a resident of one Contracting State arising in the other Contracting State and not dealt with in the preceding articles of the Convention may be taxed in that other State, serving as a residual rule permitting the source State to tax cross border income not covered elsewhere in the treaty.
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: treaty permits source state to tax income not covered elsewhere under the convention.
Article 22 provides that items of income of a resident of one Contracting State arising in the other Contracting State and not dealt with in the preceding articles of the Convention may be taxed in that other State, serving as a residual rule permitting the source State to tax cross border income not covered elsewhere in the treaty.
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