Taxation of other income: generally taxable only in resident state, except where linked to a permanent establishment or fixed base. Article 23 provides that income of a resident not covered elsewhere in the Agreement is generally taxable only in the resident State, but where such income (other than immovable property income) arises in the other Contracting State and is effectively connected with a permanent establishment or fixed base through which the resident carries on business or performs independent personal services, Article 7 or Article 15 applies; the competent authorities may consult and develop bilateral procedures to implement the mutual agreement procedure.
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: generally taxable only in resident state, except where linked to a permanent establishment or fixed base.
Article 23 provides that income of a resident not covered elsewhere in the Agreement is generally taxable only in the resident State, but where such income (other than immovable property income) arises in the other Contracting State and is effectively connected with a permanent establishment or fixed base through which the resident carries on business or performs independent personal services, Article 7 or Article 15 applies; the competent authorities may consult and develop bilateral procedures to implement the mutual agreement procedure.
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