Taxation of other income: residence is primary, but source taxation may apply when effectively connected to a permanent establishment. Undealt-with items of income of a resident are generally taxable only in the State of residence, except where 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, in which case the provisions on business profits or independent personal services apply; notwithstanding these rules, such income arising in the other State may be taxed there, and competent authorities shall consult and develop bilateral procedures to implement the mutual agreement procedure.
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 is primary, but source taxation may apply when effectively connected to a permanent establishment.
Undealt-with items of income of a resident are generally taxable only in the State of residence, except where 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, in which case the provisions on business profits or independent personal services apply; notwithstanding these rules, such income arising in the other State may be taxed there, and competent authorities shall consult and develop bilateral procedures to implement the mutual agreement procedure.
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