Other income taxation: residence generally taxed, but source state may tax gambling and PE connected income. Article 22 establishes that other income of a resident is generally taxable only in the resident State, except where such income (excluding immovable property income) is effectively connected with a permanent establishment or fixed base in the other Contracting State, in which case Articles 7 or 14 apply; additionally, income from lotteries, betting and other gambling sourced in the other State may be taxed by that State.
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Provisions expressly mentioned in the judgment/order text.
Other income taxation: residence generally taxed, but source state may tax gambling and PE connected income.
Article 22 establishes that other income of a resident is generally taxable only in the resident State, except where such income (excluding immovable property income) is effectively connected with a permanent establishment or fixed base in the other Contracting State, in which case Articles 7 or 14 apply; additionally, income from lotteries, betting and other gambling sourced in the other State may be taxed by that State.
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