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ARTICLE 21

U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996 · 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 (Immovable 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, or performs in that other State independent personal services from a fixed base situated therein, and the income is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.

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▸Contents — U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996
U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996

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