Other income taxation: residence-based taxation yields to source taxation when effectively connected to a permanent establishment or fixed base. Items of income of a resident not expressly dealt with in the Convention are generally taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or a fixed base in the other State, in which case the rules on business profits or independent personal services apply; additionally, the State where the income arises may tax items not covered by prior articles.
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.
Other income taxation: residence-based taxation yields to source taxation when effectively connected to a permanent establishment or fixed base.
Items of income of a resident not expressly dealt with in the Convention are generally taxable only in the resident State, except where such income (other than immovable property income) is effectively connected with a permanent establishment or a fixed base in the other State, in which case the rules on business profits or independent personal services apply; additionally, the State where the income arises may tax items not covered by prior articles.
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