Taxation of other income: residence state generally taxed; source state may tax if effectively connected to PE or fixed base. Income of a resident not expressly covered by other Convention provisions is generally taxable only in the State of residence. However, 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 income is taxable under the rules for business profits or independent personal services; the source State may also tax items of such income arising in its territory as permitted by the Convention.
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.
Taxation of other income: residence state generally taxed; source state may tax if effectively connected to PE or fixed base.
Income of a resident not expressly covered by other Convention provisions is generally taxable only in the State of residence. However, 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 income is taxable under the rules for business profits or independent personal services; the source State may also tax items of such income arising in its territory as permitted by the Convention.
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