Taxation of other income: residence-based taxation subject to permanent establishment or fixed-base effective-connection exceptions. Items of income of a resident not addressed in other treaty articles are generally taxable only in the resident State; however, if the recipient conducts business through a permanent establishment or renders independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply. Additionally, income not dealt with elsewhere that arises in the source State may also be taxed by that source State notwithstanding the residence rule.
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: residence-based taxation subject to permanent establishment or fixed-base effective-connection exceptions.
Items of income of a resident not addressed in other treaty articles are generally taxable only in the resident State; however, if the recipient conducts business through a permanent establishment or renders independent personal services from a fixed base in the other State and the income is effectively connected with that permanent establishment or fixed base, the rules on business profits or independent personal services apply. Additionally, income not dealt with elsewhere that arises in the source State may also be taxed by that source State notwithstanding the residence rule.
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