Other income taxation: residence-based rule with source-state taxation where linked to a permanent establishment or gambling. Income of a resident not dealt with in earlier Articles is generally taxable only in the resident State. Exceptions: non-immovable income effectively ... Summary
Other income taxation: residence-based rule with source-state taxation where linked to a permanent establishment or gambling.
Income of a resident not dealt with in earlier Articles is generally taxable only in the resident State. Exceptions: non-immovable income effectively connected with a permanent establishment or fixed base in the other State is governed by Article 7 or Article 14; and income from lotteries, betting, gambling and similar games sourced in the other State may be taxed by that source State.
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