Residence-based taxation: residual income items are taxable only in the resident state under the treaty. Items of income of a resident that are not dealt with in the other Articles of the Convention shall, wherever arising, be taxable only in the resident Contracting State; this residual rule assigns exclusive taxing authority to the state of residence for income categories not expressly allocated by the treaty.
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Provisions expressly mentioned in the judgment/order text.
Residence-based taxation: residual income items are taxable only in the resident state under the treaty.
Items of income of a resident that are not dealt with in the other Articles of the Convention shall, wherever arising, be taxable only in the resident Contracting State; this residual rule assigns exclusive taxing authority to the state of residence for income categories not expressly allocated by the treaty.
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