Income not expressly mentioned: taxable only in the resident State under the DTAA, preserving exclusive taxing rights. Article 24 provides that items of income of a resident of a Contracting State not expressly mentioned in the preceding Articles, and which are subject to tax in that resident State, shall be taxable only in that resident State, thereby conferring an exclusive taxing right on the State of residence for unspecified categories of income under the DTAA.
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.
Income not expressly mentioned: taxable only in the resident State under the DTAA, preserving exclusive taxing rights.
Article 24 provides that items of income of a resident of a Contracting State not expressly mentioned in the preceding Articles, and which are subject to tax in that resident State, shall be taxable only in that resident State, thereby conferring an exclusive taxing right on the State of residence for unspecified categories of income under the DTAA.
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