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 ... Summary
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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