Items of income which are not mentioned in a treaty, by default, fall to be taxed in accordance with the domestic laws of the contracting states. Treaties patterned on the OECD Model attempt to sweep up this residual category through the ‘Other Income’ article. The simplest form of this article is found in the UK-Sudan Treaty, art. 21, which reads:

‘Items of income of a resident of a Contracting State being income of a class or from sources not expressly mentioned in the foregoing Articles of this Convention shall be taxable only in that State.’

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