Other income: general residence taxation rule with exceptions for permanent establishments, fixed bases, and gambling income taxable at source. Items of income of a resident not dealt with elsewhere are generally taxable only in the resident State. Exceptions: income (other than immovable property) connected with a permanent establishment or fixed base in the other State is governed by Article 7 or 14; and income from lotteries, races, games or any form of gambling sourced in the other State may be taxed in that other State.
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: general residence taxation rule with exceptions for permanent establishments, fixed bases, and gambling income taxable at source.
Items of income of a resident not dealt with elsewhere are generally taxable only in the resident State. Exceptions: income (other than immovable property) connected with a permanent establishment or fixed base in the other State is governed by Article 7 or 14; and income from lotteries, races, games or any form of gambling sourced in the other State may be taxed in that other State.
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