Income not expressly mentioned: residence-based taxation applies, taxing such income only in the resident State. Income of a resident of a Contracting State not dealt with in the other Articles of the Syria DTAA is taxable only in the State of residence; the provision allocates exclusive taxing rights over uncategorised or residual income to the recipient's Contracting State regardless of where the income arises.
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.
Income not expressly mentioned: residence-based taxation applies, taxing such income only in the resident State.
Income of a resident of a Contracting State not dealt with in the other Articles of the Syria DTAA is taxable only in the State of residence; the provision allocates exclusive taxing rights over uncategorised or residual income to the recipient's Contracting State regardless of where the income arises.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.