Taxation of other income: residence-based rule with exceptions for PE/fixed base connections and lottery winnings. Other income of a resident not dealt with elsewhere is taxable only in the resident State, subject to two exceptions: income (other than immovable property income) effectively connected with a permanent establishment or arising from independent personal services from a fixed base in the other State is taxable under Article 7 or Article 14; and winnings from lotteries, betting and similar games sourced in the other State may be taxed in 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: residence-based rule with exceptions for PE/fixed base connections and lottery winnings.
Other income of a resident not dealt with elsewhere is taxable only in the resident State, subject to two exceptions: income (other than immovable property income) effectively connected with a permanent establishment or arising from independent personal services from a fixed base in the other State is taxable under Article 7 or Article 14; and winnings from lotteries, betting and similar games sourced in the other State may be taxed in that State.
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