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of <h1>Double Tax Agreement: Article 23 Explains Taxation of Unspecified Income, With Exceptions for Business Ties and Local Income.</h1> Article 23 of the Double Tax Avoidance Agreement between two Contracting States addresses the taxation of other income not covered by previous Articles. Generally, such income is taxable only in the resident's State. However, if the income is linked to a business or independent personal services conducted through a permanent establishment or fixed base in the other State, the provisions of Articles 7 or 15 apply. Additionally, income not covered by previous Articles and arising in the other State may also be taxed there, notwithstanding the general rule.
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