Residence principle extends treaty coverage to residents and fiscally transparent entities when income is taxed as the resident's. The Convention applies to persons who are residents of one or both Contracting States. Income derived by or through an entity or arrangement treated as wholly or partly fiscally transparent is considered income of a resident of a Contracting State only to the extent that the State treats that income as the resident's income for taxation. The Convention does not affect a State's taxation of its residents except with respect to benefits expressly provided in specified treaty Articles.
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.
Residence principle extends treaty coverage to residents and fiscally transparent entities when income is taxed as the resident's.
The Convention applies to persons who are residents of one or both Contracting States. Income derived by or through an entity or arrangement treated as wholly or partly fiscally transparent is considered income of a resident of a Contracting State only to the extent that the State treats that income as the resident's income for taxation. The Convention does not affect a State's taxation of its residents except with respect to benefits expressly provided in specified treaty Articles.
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