Other income taxation: resident's unspecified income generally taxable only in residence state, with permanent establishment exceptions. Items of other income of a resident not expressly dealt with elsewhere in the Convention are generally taxable only in the resident State. If 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, the source State may tax the income under the rules for business profits or independent personal services.
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 taxation: resident's unspecified income generally taxable only in residence state, with permanent establishment exceptions.
Items of other income of a resident not expressly dealt with elsewhere in the Convention are generally taxable only in the resident State. If 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, the source State may tax the income under the rules for business profits or independent personal services.
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