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 ... Summary
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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