Other income taxation: residence generally has exclusive taxing right; source may tax if income attributable to a permanent establishment. Items of income of a resident not addressed elsewhere in the Convention are generally taxable only in the resident State, except where the resident ... Summary
Other income taxation: residence generally has exclusive taxing right; source may tax if income attributable to a permanent establishment.
Items of income of a resident not addressed elsewhere in the Convention are generally taxable only in the resident State, except where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State; in that case income attributable to the permanent establishment or fixed base is taxed under the Articles on Business Profits or Independent Personal Services. Notwithstanding those rules, the other State may also tax items of such income arising in its territory.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
