Taxation of other income: residents' unspecified income taxed at residence, with PE connected and gambling income taxable at source. Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where income (other than immovable property) is effectively connected with a permanent establishment or fixed base in the other State, in which case the treaty provisions on business profits or independent personal services apply; income from lotteries and gambling arising in the other State may be taxed by that 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.
Taxation of other income: residents' unspecified income taxed at residence, with PE connected and gambling income taxable at source.
Items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where income (other than immovable property) is effectively connected with a permanent establishment or fixed base in the other State, in which case the treaty provisions on business profits or independent personal services apply; income from lotteries and gambling arising in the other State may be taxed by that State.
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