Other income allocation: residents taxed only in their State unless income is effectively connected with a permanent establishment. Income of a resident not dealt with elsewhere in the Convention is taxable only in the State of residence, except where such income (other than from immovable property) is effectively connected with a permanent establishment or fixed base in the other State; in that case Articles 7 or 14 apply.
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 allocation: residents taxed only in their State unless income is effectively connected with a permanent establishment.
Income of a resident not dealt with elsewhere in the Convention is taxable only in the State of residence, except where such income (other than from immovable property) is effectively connected with a permanent establishment or fixed base in the other State; in that case Articles 7 or 14 apply.
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