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.
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 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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