Taxation of other income: residence-based taxation with PE or fixed base exceptions permitting source-state taxation where effectively connected. Article 22 provides that items of income of a resident not expressly dealt with in earlier articles are taxable only in the State of residence, except where such income (other than income from immovable property) is connected with a business carried on through a permanent establishment or with independent personal services from a fixed base in the other State and the right of property is effectively connected with that establishment or base, in which case rules on business profits or independent personal services apply; nonetheless such income arising in the other State may also be taxed there.
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-based taxation with PE or fixed base exceptions permitting source-state taxation where effectively connected.
Article 22 provides that items of income of a resident not expressly dealt with in earlier articles are taxable only in the State of residence, except where such income (other than income from immovable property) is connected with a business carried on through a permanent establishment or with independent personal services from a fixed base in the other State and the right of property is effectively connected with that establishment or base, in which case rules on business profits or independent personal services apply; nonetheless such income arising in the other State may also be taxed there.
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