Taxation of other income: residents taxed in state of residence, except income linked to permanent establishments or gambling. Article 22 allocates primary taxing rights over items of other income to the recipient's State of residence, wherever arising, unless the income is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles 7 or 14 apply; income from lotteries, betting and similar games sourced in the other State may be taxed by that 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: residents taxed in state of residence, except income linked to permanent establishments or gambling.
Article 22 allocates primary taxing rights over items of other income to the recipient's State of residence, wherever arising, unless the income is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles 7 or 14 apply; income from lotteries, betting and similar games sourced in the other State may be taxed by that source State.
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