Other income taxation: resident State holds primary taxing right, but source State may also tax income from its sources. Article 22 provides that income of a resident not covered by prior Articles is taxable primarily in the resident Contracting State, but where such income ... Summary
Other income taxation: resident State holds primary taxing right, but source State may also tax income from its sources.
Article 22 provides that income of a resident not covered by prior Articles is taxable primarily in the resident Contracting State, but where such income is derived from sources in the other Contracting State that other State may also tax it, permitting concurrent source-based taxation alongside residency-based primary taxation under the DTAA.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.