Taxation of other income: residence-state tax subject to source-state taxation if effectively connected to a permanent establishment. Income of a resident not dealt with by other Convention articles is generally taxable only in the resident State, except where the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income-generating right or property is effectively connected with that permanent establishment or fixed base, in which case the rules on business profits or independent personal services apply and the source State may tax such income.
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 tax subject to source-state taxation if effectively connected to a permanent establishment.
Income of a resident not dealt with by other Convention articles is generally taxable only in the resident State, except where the recipient carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the income-generating right or property is effectively connected with that permanent establishment or fixed base, in which case the rules on business profits or independent personal services apply and the source State may tax such income.
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