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UNITED STATES MODEL INCOME TAX CONVENTION OF NOVEMBER 15, 2006

Article 21

U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

OTHER INCOME

  1. Items of income beneficially owned by a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.

  2. The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6 (Income from Real Property), if the beneficial owner of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein and the income is attributable to such permanent establishment. In such case the provisions of Article 7 (Business Profits) shall apply.

2006 U.S. Model Income Tax Convention

  • 31

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▸Contents — U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf
U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf

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