Source of income: income taxable in the other State under the treaty is treated as sourced there for tax purposes. Income of a resident that may be taxed in the other Contracting State under the treaty is deemed, for the other State's domestic tax law, to be income from sources in that other State; the same deemed sourcing applies for the resident's State for purposes of Article 24 and its domestic tax law.
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.
Source of income: income taxable in the other State under the treaty is treated as sourced there for tax purposes.
Income of a resident that may be taxed in the other Contracting State under the treaty is deemed, for the other State's domestic tax law, to be income from sources in that other State; the same deemed sourcing applies for the resident's State for purposes of Article 24 and its domestic tax law.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.