Taxation of other income: resident-state taxation subject to permanent establishment or fixed base exceptions and gambling taxed at source. Article 23 prescribes that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where the income (other than immovable property) is effectively connected with a permanent establishment or a fixed base in the other State-in which case rules for business profits or independent personal services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed in that source 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: resident-state taxation subject to permanent establishment or fixed base exceptions and gambling taxed at source.
Article 23 prescribes that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where the income (other than immovable property) is effectively connected with a permanent establishment or a fixed base in the other State-in which case rules for business profits or independent personal services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed in that source State.
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