Other income may be taxed in the Contracting State when such income is not addressed by earlier treaty provisions. Article 21 provides that items of income arising in a Contracting State which are not dealt with in the foregoing Articles of the DTAA may be taxed in that State, functioning as a residual clause permitting the source State to tax income not otherwise allocated by the Agreement.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Other income may be taxed in the Contracting State when such income is not addressed by earlier treaty provisions.
Article 21 provides that items of income arising in a Contracting State which are not dealt with in the foregoing Articles of the DTAA may be taxed in that State, functioning as a residual clause permitting the source State to tax income not otherwise allocated by the Agreement.
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