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of <h1>Article 23 of DTAA: 'Other Income' Taxable Only in Resident State Unless Linked to Permanent Establishment.</h1> Article 23 of the Double Taxation Avoidance Agreement (DTAA) between the UK and another Contracting State addresses the taxation of 'other income.' Generally, income beneficially owned by a resident of a Contracting State is taxable only in that State, unless it arises from business activities through a permanent establishment or fixed base in the other State. In such cases, Articles 7 or 15 apply. Additionally, income not specifically covered in other articles of the Convention, and arising in the other Contracting State, may also be taxed in that State.
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