Residence-based taxation of other income may be overridden where effectively connected to a permanent establishment or fixed base. Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where the resident carries on business through a ... Summary
Residence-based taxation of other income may be overridden where effectively connected to a permanent establishment or fixed base.
Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where the resident 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 fixed base, in which case rules for business profits or independent personal services apply; notwithstanding these provisions, such other income arising in the other State may also be taxed in that other State.
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