INCOME NOT EXPRESSLY MENTIONED. (1) Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State. (2) However, any such income derived by a resident of one of the Contracting State may also he taxed in that other State. (3) The provisions of paragraph (1) shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a case, the provisions of Article 7 or 14, as the case may be, shall apply.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
INCOME NOT EXPRESSLY MENTIONED. (1) Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) However, any such income derived by a resident of one of the Contracting States from sources in the other Contracting State may also he be taxed in that other State.
(3) The provisions of paragraph (1) shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
Appears in 3 contracts
Samples: International Tax Agreements, Income Tax Agreement, International Tax Agreements
INCOME NOT EXPRESSLY MENTIONED. (1) . Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) . However, any such income derived by a resident of one of the Contracting States from sources in the other Contracting State may also he be taxed in that other State.
(3) . The provisions of paragraph (1) 1 shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a that case, the provisions of Article 7 or 14, as the case may be, shall apply.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
INCOME NOT EXPRESSLY MENTIONED. (1) . Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) . However, any such income derived by a resident of one of the Contracting States from sources in the other Contracting State may also he be taxed in that other State.
(3) . The provisions of paragraph (1) shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
INCOME NOT EXPRESSLY MENTIONED. (1) . Items of income of a resident of one of the a Contracting States State which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) . However, any such income derived by a resident of one of a Contracting State from sources in the other Contracting State may also he be taxed in that other State.
(3) . The provisions of paragraph (1) 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6, derived by a resident of one of the a Contracting States State where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a that case, the provisions of Article 7 or Article 14, as the case may be, shall apply.. Article
Appears in 1 contract
Samples: Income Tax Agreement
INCOME NOT EXPRESSLY MENTIONED. (1) . Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) . However, any such income derived by a resident of one of the Contracting States from sources in the other Contracting State may also he be taxed in that other State.
(3) . The provisions of paragraph (1) 1 shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
Appears in 1 contract
Samples: Double Taxation Agreement
