Taxation of other income: residence-state primary right, but source-state may tax if effectively connected to a permanent establishment. Article 23 provides that items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where such income ... Summary
Taxation of other income: residence-state primary right, but source-state may tax if effectively connected to a permanent establishment.
Article 23 provides that items of income of a resident not dealt with elsewhere are taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State, in which case rules on business profits or independent personal services apply; notwithstanding this, such items may also be taxed in the other State.
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