Residence-based taxation of other income, with PE or fixed base connection allowing source-state taxation under business or services rules. Income of a resident not dealt with elsewhere in the treaty is generally taxable only in the State of residence, except that income (other than immovable property) that is effectively connected with a permanent establishment or fixed base in the other State is governed by Article 7 or 14; additionally, such 'other income' arising in the other State may also be taxed in that other 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.
Residence-based taxation of other income, with PE or fixed base connection allowing source-state taxation under business or services rules.
Income of a resident not dealt with elsewhere in the treaty is generally taxable only in the State of residence, except that income (other than immovable property) that is effectively connected with a permanent establishment or fixed base in the other State is governed by Article 7 or 14; additionally, such "other income" arising in the other State may also be taxed in that other State.
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