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 ... Summary
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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