Other income: residual treaty category allowing both Contracting States to tax income not allocated by earlier provisions. Article 23 provides that Other Income, meaning income of a resident not dealt with in earlier Articles of the Convention, may be taxed in both Contracting States as a residual category, leaving concurrent taxing rights where no prior treaty allocation applies.
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Provisions expressly mentioned in the judgment/order text.
Other income: residual treaty category allowing both Contracting States to tax income not allocated by earlier provisions.
Article 23 provides that Other Income, meaning income of a resident not dealt with in earlier Articles of the Convention, may be taxed in both Contracting States as a residual category, leaving concurrent taxing rights where no prior treaty allocation applies.
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