Taxation of other income: residence generally has primary taxing right, except where effective connection with a permanent establishment shifts allocation. Under the treaty, items of a resident's income not covered elsewhere are taxable only in the State of residence, except where such income arising in the other State is effectively connected with a permanent establishment or fixed base used for business or independent personal services, in which case rules on business profits or independent personal services apply; additionally the source State retains power to tax resident's income arising in its territory where not otherwise dealt with in the Convention.
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 generally has primary taxing right, except where effective connection with a permanent establishment shifts allocation.
Under the treaty, items of a resident's income not covered elsewhere are taxable only in the State of residence, except where such income arising in the other State is effectively connected with a permanent establishment or fixed base used for business or independent personal services, in which case rules on business profits or independent personal services apply; additionally the source State retains power to tax resident's income arising in its territory where not otherwise dealt with in the Convention.
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