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HMRC internal manual

International Manual

Description of double taxation agreements: Other income

This Article covers items of income (but not capital gains) which are not covered in the other Articles of an agreement. Examples of items of income which come within this Article are, alimony and social security pensions (unless these have been dealt with in another Article), payments under deed’s of covenant and income arising in third countries.

The Article normally provides that such income is taxable only in the country of which the recipient is a resident. Some agreements vary so the provision in particular treaties should be checked as necessary.

In many agreements the Article excludes income paid out of trusts or estates in the course of administration. This prevents a beneficiary of a discretionary trust who is a resident of the United Kingdom’s agreement partner from claiming repayment of all the additional and basic rate tax charged on the trustees under ITA07/S479 and ITA07/S481. ESC/B18, however, enables such a beneficiary to `look through’ to the income underlying the payments made to him and the appropriate Article in the agreement will apply to any such income arising in the United Kingdom. See INTM367820 onwards.