Taxation of other income: residence-state primary taxation, but source-state may tax if linked to a permanent establishment. Items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State; however, if the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules for business profits or independent personal services apply, and additionally such income arising in the other State may also be taxed there.
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: residence-state primary taxation, but source-state may tax if linked to a permanent establishment.
Items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State; however, if the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, the rules for business profits or independent personal services apply, and additionally such income arising in the other State may also be taxed there.
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