Taxation of other income: resident taxation is default, but source taxation may apply if effectively connected to a PE or fixed base. Other income of a resident not dealt with in other articles is generally taxable only in the State of residence. If the recipient carries on business ... Summary
Taxation of other income: resident taxation is default, but source taxation may apply if effectively connected to a PE or fixed base.
Other income of a resident not dealt with in other articles is generally taxable only in the State of residence. If the recipient 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 with that permanent establishment or fixed base, the source State may tax such income under the rules applicable to business profits or independent personal services; additionally, such other income arising in the other State may also be taxed there in specified cases.
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