Taxation of other income: residence-state generally taxes, but income effectively connected to a PE or fixed base may be taxed by source state. Items of income of a resident not specifically addressed in the Convention are generally taxable only in the State of residence, but income (other than specified immovable property income) that is effectively connected with a permanent establishment or fixed base in the other State is taxed under the rules for business profits or independent personal services; notwithstanding those rules, income of a resident arising in the other State and not dealt with elsewhere may also 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.
Taxation of other income: residence-state generally taxes, but income effectively connected to a PE or fixed base may be taxed by source state.
Items of income of a resident not specifically addressed in the Convention are generally taxable only in the State of residence, but income (other than specified immovable property income) that is effectively connected with a permanent establishment or fixed base in the other State is taxed under the rules for business profits or independent personal services; notwithstanding those rules, income of a resident arising in the other State and not dealt with elsewhere may also be taxed in that other State.
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