Source-based taxation: income not covered by other treaty provisions is taxable only in the source State under the DTAA. Article 22 of the Namibia DTAA provides a residual allocation rule: items of income not dealt with in preceding articles and derived from sources within a Contracting State are taxable only in that State, ensuring that income not otherwise characterised by the Convention remains taxable where it arises.
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.
Source-based taxation: income not covered by other treaty provisions is taxable only in the source State under the DTAA.
Article 22 of the Namibia DTAA provides a residual allocation rule: items of income not dealt with in preceding articles and derived from sources within a Contracting State are taxable only in that State, ensuring that income not otherwise characterised by the Convention remains taxable where it arises.
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