Taxation of unspecified income: residence-based exclusive taxing right under the treaty for residual income items. Article 22 provides that items of income of a resident of a Contracting State not expressly mentioned in preceding Articles shall be taxable only in that ... Summary
Taxation of unspecified income: residence-based exclusive taxing right under the treaty for residual income items.
Article 22 provides that items of income of a resident of a Contracting State not expressly mentioned in preceding Articles shall be taxable only in that State, functioning as a residuary rule that allocates exclusive taxing rights over unspecified or residual income to the State of residence under the tax treaty.
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