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Other income taxation: generally taxable only in the resident state, except PE-connected income and local lottery winnings. Other income of a resident is generally taxable only in the resident Contracting State, except where the beneficial owner 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 permanent establishment or fixed base, in which case business profits or independent personal services rules apply; lottery and similar gaming winnings may be taxed where they arise.
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: generally taxable only in the resident state, except PE-connected income and local lottery winnings.
Other income of a resident is generally taxable only in the resident Contracting State, except where the beneficial owner 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 permanent establishment or fixed base, in which case business profits or independent personal services rules apply; lottery and similar gaming winnings may be taxed where they arise.
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