Other income taxation allocates primary residence-state taxing rights, subject to permanent establishment, fixed base, and source-state taxation. Other income of a resident of either Contracting State, not expressly covered by other treaty provisions, is taxable only in the resident's Contracting ... Summary
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Other income taxation allocates primary residence-state taxing rights, subject to permanent establishment, fixed base, and source-state taxation.
Other income of a resident of either Contracting State, not expressly covered by other treaty provisions, is taxable only in the resident's Contracting State. This rule does not apply, except for defined immovable-property income, where income is effectively connected with a permanent establishment or fixed base in the other Contracting State; business profits or independent personal-services provisions then govern. Other income arising in the other Contracting State may also be taxed there.
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