Taxation of other income: generally taxable in the recipient's residence, with PE connections and gambling taxable at source. Other income not provided for elsewhere in the Agreement is taxable only in the State of which the recipient is a resident, subject to the exception that income (other than immovable property income) which is effectively connected with a permanent establishment or derived from independent personal services performed from a fixed base in the other Contracting State is taxed under the rules for business profits or independent personal services; receipts from lotteries, gambling 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: generally taxable in the recipient's residence, with PE connections and gambling taxable at source.
Other income not provided for elsewhere in the Agreement is taxable only in the State of which the recipient is a resident, subject to the exception that income (other than immovable property income) which is effectively connected with a permanent establishment or derived from independent personal services performed from a fixed base in the other Contracting State is taxed under the rules for business profits or independent personal services; receipts from lotteries, gambling and similar games sourced in the other State may be taxed by that source State.
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