Taxation of other income: residence generally governs tax rights, subject to permanent establishment connection allowing source taxation. Income of a resident not dealt with elsewhere in the treaty is generally taxable only in the resident Contracting State. If the resident carries on ... Summary
Taxation of other income: residence generally governs tax rights, subject to permanent establishment connection allowing source taxation.
Income of a resident not dealt with elsewhere in the treaty is generally taxable only in the resident Contracting State. If the resident 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, the provisions on business profits or independent personal services apply and the other State may tax the income.
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