Tax Home principle: income is treated as arising in the Contracting State where it originates under the DTAA. The Tax Home principle treats the jurisdictional attachment of income for taxation purposes as the Contracting State in which the income arises, subject to other provisions of the Convention, thereby allocating treaty taxing entitlement by reference to the source of the 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.
Tax Home principle: income is treated as arising in the Contracting State where it originates under the DTAA.
The Tax Home principle treats the jurisdictional attachment of income for taxation purposes as the Contracting State in which the income arises, subject to other provisions of the Convention, thereby allocating treaty taxing entitlement by reference to the source of the income.
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