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of <h1>Comprehensive Framework for Taxing Unspecified Income: Balancing Resident State Primacy with Source State Rights under Article 21</h1> The UN Model Double Taxation Avoidance Agreement Article 21 addresses taxation of other income not specifically covered in previous articles. Income of a resident is primarily taxable in their home state. However, if the income is connected to a permanent establishment or fixed base in another state, that state may also tax the income. Additionally, income arising in another state can be taxed by that state under certain conditions.
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