Taxation of other income: generally taxable in the resident state, but source state may tax if effectively connected to presence. Income of a resident not expressly covered elsewhere in the Convention is generally taxable only in the State of residence. If such income (excluding immovable property income) is connected with a permanent establishment or a fixed base in the other State-because the resident carries on business there or performs independent personal services from that fixed base-and the right or property yielding the income is effectively connected with that establishment or base, then provisions governing business profits or independent personal services apply. Notwithstanding those rules, such unspecified income arising in the other State may also 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.
Taxation of other income: generally taxable in the resident state, but source state may tax if effectively connected to presence.
Income of a resident not expressly covered elsewhere in the Convention is generally taxable only in the State of residence. If such income (excluding immovable property income) is connected with a permanent establishment or a fixed base in the other State-because the resident carries on business there or performs independent personal services from that fixed base-and the right or property yielding the income is effectively connected with that establishment or base, then provisions governing business profits or independent personal services apply. Notwithstanding those rules, such unspecified income arising in the other State may also be taxed in that other State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
