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Other income allocation: resident-state taxation generally, except for permanent establishment connections and source taxation of gambling. Income of a resident not dealt with elsewhere in the Convention is taxable only in the State of residence, except where the beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base; in that case the provisions 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 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 allocation: resident-state taxation generally, except for permanent establishment connections and source taxation of gambling.
Income of a resident not dealt with elsewhere in the Convention is taxable only in the State of residence, except where the beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base; in that case the provisions 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 State.
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