Taxation of other income: residence state primary, but permanent establishment links can permit source-state taxation. Income of a resident not dealt with elsewhere in the Convention is generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-in which case Articles 7 or 15 apply-and notwithstanding those provisions the other State may tax items of resident income arising 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, but permanent establishment links can permit source-state taxation.
Income of a resident not dealt with elsewhere in the Convention is generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-in which case Articles 7 or 15 apply-and notwithstanding those provisions the other State may tax items of resident income arising there.
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