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Article 21. OTHER INCOME

U.S. Income Tax Treaty — Ukraine Technical Explanation – 1994 · 2026-10-03 edition · updated 2026-10-04 · United States

This Article provides the rules for the taxation of items of income not dealt with in the other articles of the Convention, such as alimony, child support payments, lottery winnings, punitive damages, and cancellation of indebtedness income.

Paragraph 1 contains the general rule that items of income derived by a resident of a Contracting State and not dealt with elsewhere in the Convention may be taxed only in the State of residence. This exclusive right of taxation applies irrespective of the source of the income.

Paragraph 2 contains an exception to the general rule of paragraph 1 for income that is attributable to a permanent establishment or fixed base that is or was maintained in a Contracting State by a resident of the other Contracting State. The taxation of such income is governed by the provisions of Articles 7 (Business Profits) or 14 (Independent Personal Services). For example, other income, wherever arising, that is attributable to a permanent establishment that is or was maintained in the United States by a resident of Ukraine would be taxable by the United States.

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▸Contents — U.S. Income Tax Treaty — Ukraine Technical Explanation – 1994
U.S. Income Tax Treaty — Ukraine Technical Explanation – 1994

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