Other income taxation: residence-based rule with permanent establishment exceptions and source taxation for gambling proceeds. Other income of a resident not dealt with elsewhere is taxable only in the State of residence, except where such income (other than immovable property) is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles on business profits or independent personal services apply; income from lotteries, gambling and similar games sourced in the other State may be taxed by that source State.
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 rule with permanent establishment exceptions and source taxation for gambling proceeds.
Other income of a resident not dealt with elsewhere is taxable only in the State of residence, except where such income (other than immovable property) is effectively connected with a permanent establishment or fixed base in the other State, in which case Articles on business profits or independent personal services apply; income from lotteries, gambling and similar games sourced in the other State may be taxed by that source State.
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