DT6526 - DT: Egypt: double taxation agreement, Article 27: Miscellaneous rules


  1. Where under any provision of this Convention income arising in one of the Contracting States is relieved from tax in that Contracting State and, under the law in force in the other Contracting State a person, in respect of the said income, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first- mentioned Contracting State shall apply only to so much of the income as is remitted to or received in the other Contracting State.

  2. Items of income of a resident of a Contracting State, wherever arising being income of a class or from sources not expressly mentioned in this Convention shall be taxable only in that State.