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.
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.
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.
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