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of <h1>Article 22 of DTAA: Taxation of Unspecified Income for Residents, Exceptions for Permanent Establishments Apply</h1> Article 22 of the Double Tax Avoidance Agreement (DTAA) between two contracting parties addresses the taxation of income not covered by previous articles. Generally, such income for a resident of one party is taxable only in that party. However, if the income is connected to a business or services conducted through a permanent establishment or fixed base in the other party, Articles 7 or 15 apply, allowing taxation in that other party. Despite these rules, income not previously addressed and arising in the other contracting party may also be taxed there.
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