https://www.taxtmi.com/acts?id=18957 Article 22 makes residency the primary taxing right for items of income not covered elsewhere in the Treaty, but provides that where a 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 presence, the provisions on business profits or independent personal services (Article 7 or Article 14) apply; additionally, the other State retains a residual right to tax such income arising within its territory. en-us Mon, 01 Sep 2014 13:09:13 +0530 Mon, 18 Nov 2024 16:39:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18957 Article 22 makes residency the primary taxing right for items of income not covered elsewhere in the Treaty, but provides that where a 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 presence, the provisions on business profits or independent personal services (Article 7 or Article 14) apply; additionally, the other State retains a residual right to tax such income arising within its territory. Act-Rules DTAA Mon, 01 Sep 2014 13:09:13 +0530 https://www.taxtmi.com/acts?id=18957