ARTICLE 21

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

Income Not Expressly Mentioned

This Article provides that items of income derived by a resident of one of the Contracting States and not covered in the preceding articles may be taxed by the country of residence of the recipient. If from sources in the other State, such income may also be taxed by that other State. However, Article 7 (Business Profits) governs the taxation of such income to the extent it is

effectively connected with a permanent establishment in that other State.

Among the items covered by this Article are prizes and income from the insurance business, which is specifically excluded from the provisions of Article 7 (Business Profits) by paragraph 8 of that Article. The source of such items of income is determined under the respective domestic laws of the two countries. Any difficulties or doubts in applying this Article, as in other cases, may be addressed in accordance with the provisions of Article 24 (Mutual Agreement Procedure).

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

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

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