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Background

Many double taxation agreements contain an article that deals with income not specifically dealt with in any of the other articles in the treaty. This may be called the 鈥淥ther Income鈥� or 鈥淚ncome Not Expressly Mentioned鈥� Article.

The scope and contents of the other income article of each treaty vary. For instance, some agreements cover all income not dealt with elsewhere in the treaty. In other cases the 鈥渙ther income鈥� article may be restricted to cover only income arising in third countries. In other treaties the article may exclude income arising from trusts and settlements or from estates in the course of administration.