Residence taxation of other income: exclusive taxing right for residence state, source may tax if PE or fixed base connection.

Income not dealt with in other Convention articles is taxable in the resident State, but the source State may tax such income when the recipient carries on business in the source State through a permanent establishment and the income is effectively connected with that establishment (Article 7 on Business Profits). The UN Model additionally permits source taxation of other income and treats income connected to a fixed base for independent personal services as taxable by the source State under Article 14.

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