Taxation of unspecified income: resident State has primary right, source State may also tax; PE-linked income follows specific allocation rules. Income not expressly mentioned is taxable primarily in the taxpayer's State of residence, although the source State may also tax such income. Income effectively connected with a permanent establishment or fixed base in the source State is not covered by the primary-residence rule and is governed by the treaty provisions allocating business profits or income from a fixed base.
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 unspecified income: resident State has primary right, source State may also tax; PE-linked income follows specific allocation rules.
Income not expressly mentioned is taxable primarily in the taxpayer's State of residence, although the source State may also tax such income. Income effectively connected with a permanent establishment or fixed base in the source State is not covered by the primary-residence rule and is governed by the treaty provisions allocating business profits or income from a fixed base.
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