Taxation of Other Income: residence state primarily taxed; source state may tax estates or trusts with limited levy. Items of other income not dealt with elsewhere in the Convention are taxable only in the resident Contracting State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles 7 or 14 apply; additionally, the source State may tax other income arising there, subject to a capped tax on income from estates or certain trusts when that income is taxable in the beneficiary's residence 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: residence state primarily taxed; source state may tax estates or trusts with limited levy.
Items of other income not dealt with elsewhere in the Convention are taxable only in the resident Contracting State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles 7 or 14 apply; additionally, the source State may tax other income arising there, subject to a capped tax on income from estates or certain trusts when that income is taxable in the beneficiary's residence State.
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