Taxation of other income: residence state generally taxes such receipts, with PE/fixed base and lottery exceptions. Article 22 provides that income of a resident not covered elsewhere in the Treaty is taxable only in the resident State, except where the beneficial owner ... Summary
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.
Taxation of other income: residence state generally taxes such receipts, with PE/fixed base and lottery exceptions.
Article 22 provides that income of a resident not covered elsewhere in the Treaty is taxable only in the resident State, except where the beneficial owner carries on business via a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that PE or fixed base-then Articles on business profits or independent personal services apply-and except that winnings or prizes from lotteries, games or races may be taxed in the State where they arise.
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