Other income: residence-based taxation with PE and fixed-base exception permitting source taxation when effectively connected. Items of other income of a resident not dealt with in earlier articles are taxable only in the State of residence, subject to an exception 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 permanent establishment or fixed base, in which case the provisions on business profits or independent personal services apply; the source State may also tax residual items of income not addressed elsewhere.
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: residence-based taxation with PE and fixed-base exception permitting source taxation when effectively connected.
Items of other income of a resident not dealt with in earlier articles are taxable only in the State of residence, subject to an exception 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 permanent establishment or fixed base, in which case the provisions on business profits or independent personal services apply; the source State may also tax residual items of income not addressed elsewhere.
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