Other income taxable in resident state unless effectively connected to a permanent establishment or fixed base abroad. Other income of a resident is generally taxable only in the State of residence, except where income arising in the other Contracting State is effectively connected with a permanent establishment or a fixed base through which the resident carries on business or performs independent personal services, in which case the rules governing business profits or independent personal services apply, and notwithstanding those rules such income may also be taxed in the source State.
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.
Other income taxable in resident state unless effectively connected to a permanent establishment or fixed base abroad.
Other income of a resident is generally taxable only in the State of residence, except where income arising in the other Contracting State is effectively connected with a permanent establishment or a fixed base through which the resident carries on business or performs independent personal services, in which case the rules governing business profits or independent personal services apply, and notwithstanding those rules such income may also be taxed in the source State.
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