Other income taxation: resident's unprovided-for income taxable in residence state, except when effectively connected with a permanent establishment. Article 21 provides that items of income not dealt with elsewhere are generally taxable only in the resident State, except where the resident carries on ... Summary
Other income taxation: resident's unprovided-for income taxable in residence state, except when effectively connected with a permanent establishment.
Article 21 provides that items of income not dealt with elsewhere are generally taxable only in the resident State, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, in which case the rules for business profits or independent personal services apply; additionally, the other State may tax such income arising there notwithstanding the general rule.
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