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Taxation of other income: residency principle limits taxation to the resident state, with permanent establishment and fixed base exceptions. Primary taxing rights over other income are vested in the resident Contracting State; however, where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected to that establishment or base, the source State may tax such income under the rules for business profits or independent personal services, and a later amendment confirms that income not dealt with elsewhere may also be taxed in the State where it arises.
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Provisions expressly mentioned in the judgment/order text.
Taxation of other income: residency principle limits taxation to the resident state, with permanent establishment and fixed base exceptions.
Primary taxing rights over other income are vested in the resident Contracting State; however, where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected to that establishment or base, the source State may tax such income under the rules for business profits or independent personal services, and a later amendment confirms that income not dealt with elsewhere may also be taxed in the State where it arises.
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