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 ... Summary
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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