Taxation of other income: generally taxable only in the resident state, but effectively connected PE income follows business profits rules. Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, except where the resident carries on business in the other State through a permanent establishment and the right or property producing the income is effectively connected with that permanent establishment, in which case the business profits rules apply.
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: generally taxable only in the resident state, but effectively connected PE income follows business profits rules.
Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, except where the resident carries on business in the other State through a permanent establishment and the right or property producing the income is effectively connected with that permanent establishment, in which case the business profits rules apply.
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