Taxation of other income: residence state has primary taxing right unless effectively connected to a permanent establishment. Article 22 provides that income of a resident not addressed by other treaty articles is generally taxable only in the State of residence, except where the income is effectively connected with a permanent establishment or fixed base in the other State, in which case Article 7 or Article 14 applies; additionally, the source State may tax such income notwithstanding the primary residence rule.
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 state has primary taxing right unless effectively connected to a permanent establishment.
Article 22 provides that income of a resident not addressed by other treaty articles is generally taxable only in the State of residence, except where the income is effectively connected with a permanent establishment or fixed base in the other State, in which case Article 7 or Article 14 applies; additionally, the source State may tax such income notwithstanding the primary residence rule.
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