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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 21 of DTAA: Taxation of Unspecified Income Primarily in Resident's State, with Exceptions for Permanent Establishments.</h1> Article 21 of the Double Taxation Avoidance Agreement (DTAA) between Canada and another Contracting State addresses the taxation of income not covered in previous articles. Generally, such income is taxable only in the resident's state. Exceptions exist if the income is connected to a permanent establishment or fixed base in the other state, in which case Articles 7 or 14 apply. Additionally, income arising in the other state may be taxed there, with a cap of 15% for income from estates or certain trusts, provided it is also taxable in the beneficiary's resident state.
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