Income not expressly mentioned: taxable only in the resident State under the DTAA, preserving exclusive taxing rights.

Article 24 provides that items of income of a resident of a Contracting State not expressly mentioned in the preceding Articles, and which are subject to tax in that resident State, shall be taxable only in that resident State, thereby conferring an exclusive taxing right on the State of residence for unspecified categories of income under the DTAA.

---

---

---