Other income: taxable in the resident state unless effectively connected to a permanent establishment or fixed base. Other income of a resident is generally taxable only in the resident Contracting State, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other Contracting State and the income is effectively connected with that permanent establishment or fixed base, in which case the provisions governing business profits or independent personal services apply.
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: taxable in the resident state unless effectively connected to a permanent establishment or fixed base.
Other income of a resident is generally taxable only in the resident Contracting State, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other Contracting State and the income is effectively connected with that permanent establishment or fixed base, in which case the provisions governing business profits or independent personal services apply.
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