Other income taxation: items not covered by treaty articles taxable in resident state, except when linked to a permanent establishment. Items of income of a resident not dealt with elsewhere in the Convention are generally taxable only in the resident Contracting State, excluding immovable property. If the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules for business profits or independent personal services apply. Notwithstanding these rules, such income arising in the other Contracting State may 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.
Other income taxation: items not covered by treaty articles taxable in resident state, except when linked to a permanent establishment.
Items of income of a resident not dealt with elsewhere in the Convention are generally taxable only in the resident Contracting State, excluding immovable property. If the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules for business profits or independent personal services apply. Notwithstanding these rules, such income arising in the other Contracting State may be taxed in that other State.
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