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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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DT applications and claims - Types of income: Other income

Background

Many double taxation agreements contain an article that deals with income not specifically dealt with in any of the other articles in the treaty. This may be called the “Other Income” or “Income Not Expressly Mentioned” Article.

The scope and contents of the other income article of each treaty vary. For instance, some agreements cover all income not dealt with elsewhere in the treaty. In other cases the “other income” article may be restricted to cover only income arising in third countries. In other treaties the article may exclude income arising from trusts and settlements or from estates in the course of administration.