Other income allocation under tax treaty: residence-based taxation with PE or fixed-base connection allowing source taxation. Other income of a resident is taxable only in the resident Contracting State, except where income (other than specified immovable property income) is effectively connected with a permanent establishment or fixed base in the other Contracting State, in which case the rules on business profits or independent personal services govern taxation; notwithstanding those provisions, other income arising in the other Contracting State may nonetheless be taxed in that 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.
Other income allocation under tax treaty: residence-based taxation with PE or fixed-base connection allowing source taxation.
Other income of a resident is taxable only in the resident Contracting State, except where income (other than specified immovable property income) is effectively connected with a permanent establishment or fixed base in the other Contracting State, in which case the rules on business profits or independent personal services govern taxation; notwithstanding those provisions, other income arising in the other Contracting State may nonetheless be taxed in that State.
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