Taxation of income not expressly mentioned: primary residence taxation, with source State permitted to tax if income arises there. Income not expressly mentioned is taxable primarily in the resident State, but if such income arises in the other Contracting State that State may also tax it; the provision serves as a residual rule allocating primary residence taxation while preserving permissive source taxing rights under the treaty.
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 income not expressly mentioned: primary residence taxation, with source State permitted to tax if income arises there.
Income not expressly mentioned is taxable primarily in the resident State, but if such income arises in the other Contracting State that State may also tax it; the provision serves as a residual rule allocating primary residence taxation while preserving permissive source taxing rights under the treaty.
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