Type of income | Country allowed to tax the income |
income from interests and dividends | country of individual's real residency |
capital gains | country of individual's real residency unless sale of real property or material share in a company |
business profits | country of the company's permanent establishment |
income from real property | country in which the property is situated |
independent personal services | country where the services were earned |
employment income | country of individual's real residency. However, if he was present in the other country for more than 183 days in a tax year, or if the remuneration was paid by (or on behalf of) the employer from other country, then the other country has partial right of taxation. |
pensions | country of individual's real residency; under some circumstances the lump sum distributions from retirement accounts or pensionfunds set up under specific tax deferment schemes are allowed to be taxed in the country where the income was earned. |