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A Non-Resident Person shall be subject to corporate tax on State Sourced income which is not attributable to permanent establishment of the Non-Resident in the state.
Following incomes shall be considered as State Sourced Income:
a. Income derived from a Resident Person.
b. Income derived from a Non-Resident Person and not attributable to a Permanent Establishment of that Non-Resident Person in the State.
c. Income accrued from activities performed, assets located, capital invested, rights used, or services performed or benefitted from in the State.
State Sourced Income shall also include:
a. Income from the sale of goods and provision of services in the State.
b. Income from provision of service that are rendered or utilized or benefitted from in the State.
c. Income from a contract insofar as it has been wholly or partly performed or benefitted from in the State.
d. Income from movable or immovable property in the State.
e. Income from the disposal of shares or capital of a Resident Person.
f. Income from the use or right to use in the State, or the grant of permission to use in the State, any intellectual or intangible property.
g. Interest that meets any of the following conditions:
1) The loan is secured by movable or immovable property located in the State.
2) The borrower is a Resident Person.
3) The borrower is a Government Entity.
h. Insurance or reinsurance premiums in any of the following instances:
1) The insured asset is located in the State.
2) The insured Person is a Resident Person.
3) The insured activity is conducted in the State.
