Taxation of other income: residence taxation subject to effective connection exceptions for permanent establishments and gambling source taxation. Taxation of other income confines items not elsewhere dealt with in the Convention to the resident Contracting State; however, income (excluding immovable property) effectively connected with a permanent establishment or fixed base in the other State is taxed under the provisions for business profits or independent personal services, and income from lotteries, betting and other gambling sourced in the other State may be taxed in that source 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: residence taxation subject to effective connection exceptions for permanent establishments and gambling source taxation.
Taxation of other income confines items not elsewhere dealt with in the Convention to the resident Contracting State; however, income (excluding immovable property) effectively connected with a permanent establishment or fixed base in the other State is taxed under the provisions for business profits or independent personal services, and income from lotteries, betting and other gambling sourced in the other State may be taxed in that source State.
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