Taxation of other income: residence-based taxation applies unless income is effectively connected with a permanent establishment or fixed base. Income not expressly addressed elsewhere is taxable only in the Contracting State of the recipient's residence, except where a resident carries on business through a permanent establishment in the other State or performs independent personal services from a fixed base there and the income-producing right or property is effectively connected with that permanent establishment or fixed base; in such cases the provisions governing business profits or independent personal services apply.
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 applies unless income is effectively connected with a permanent establishment or fixed base.
Income not expressly addressed elsewhere is taxable only in the Contracting State of the recipient's residence, except where a resident carries on business through a permanent establishment in the other State or performs independent personal services from a fixed base there and the income-producing right or property is effectively connected with that permanent establishment or fixed base; in such cases the provisions governing business profits or independent personal services apply.
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