Taxation of other income: generally taxed in the resident state, except for PE/fixed base connections and source gambling taxes. Income not dealt with elsewhere in the Convention is generally taxable only in the recipient's State of residence as other income, except where the beneficial owner's income is effectively connected with a permanent establishment or fixed base in the other State (in which case business or independent services rules apply), and except that lottery, betting and other gambling receipts sourced in the other State may be taxed by 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.
Taxation of other income: generally taxed in the resident state, except for PE/fixed base connections and source gambling taxes.
Income not dealt with elsewhere in the Convention is generally taxable only in the recipient's State of residence as other income, except where the beneficial owner's income is effectively connected with a permanent establishment or fixed base in the other State (in which case business or independent services rules apply), and except that lottery, betting and other gambling receipts sourced in the other State may be taxed by that State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
