Taxation of other income: residence generally has exclusive taxing right, but source may tax gambling and PE connected income. Items of income of a resident not dealt with in other treaty provisions are taxable only in the State of residence, except where such income is effectively connected with a permanent establishment or arises from independent personal services performed from a fixed base in the other State-in which case allocation rules for business profits or independent services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed by that source 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: residence generally has exclusive taxing right, but source may tax gambling and PE connected income.
Items of income of a resident not dealt with in other treaty provisions are taxable only in the State of residence, except where such income is effectively connected with a permanent establishment or arises from independent personal services performed from a fixed base in the other State-in which case allocation rules for business profits or independent services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed by that source State.
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