Other income allocation under tax treaty: residence-based taxation, unless effectively connected to a permanent establishment or fixed base. Other income of a resident is generally taxable only in the State of residence when not dealt with elsewhere in the Convention, except where 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 establishment or base, in which case the Convention's business profits or independent personal services rules apply; additionally, the other State may tax items of income not addressed in earlier articles.
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.
Other income allocation under tax treaty: residence-based taxation, unless effectively connected to a permanent establishment or fixed base.
Other income of a resident is generally taxable only in the State of residence when not dealt with elsewhere in the Convention, except where 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 establishment or base, in which case the Convention's business profits or independent personal services rules apply; additionally, the other State may tax items of income not addressed in earlier articles.
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