Taxation of other income: residence-based taxation with exception for permanent establishments and fixed bases. The Japan DTAA provides that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where the resident 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 permanent establishment or fixed base, in which case the provisions governing business profits or independent personal services apply and the source State may tax such income.
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-based taxation with exception for permanent establishments and fixed bases.
The Japan DTAA provides that items of income of a resident not dealt with elsewhere in the Convention are taxable only in the resident State, except where the resident 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 permanent establishment or fixed base, in which case the provisions governing business profits or independent personal services apply and the source State may tax such income.
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