ARTICLE 21

U.S. Income Tax Treaty — australia tax treaty documents: aus.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Income Not Expressly Mentioned

(1) Items of income of a resident of one of the Contracting States which are not expressly mentioned in the foregoing Articles of this Convention shall be taxable only in that State.

(2) However, if such income is derived by a resident of one of the Contracting States from sources in the other Contracting State, such income may also be taxed in the State in which it has its source.

(3) The provisions of paragraph (1) shall not apply to income derived by a resident of one of the Contracting States which is effectively connected with a permanent establishment situated in the other Contracting State. In such a case, the provisions of Article 7 (Business Profits) shall apply.

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▸Contents — U.S. Income Tax Treaty — australia tax treaty documents: aus.pdf

U.S. Income Tax Treaty — australia tax treaty documents: aus.pdf

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