The article explores the evolution of France’s approach to Article 21 of the OECD Model, shedding light on the policy rationale underlying this practice. It begins by analysing the categories of income addressed by Article 21 within French treaties and examines how this article interacts with other distributive rules in French treaty practice, drawing insights from the OECD Model. In greater depth, the article investigates the interplay between the “other income” provision and specific income types, including fictitious income, business income, investment income, capital gains, trust-derived income, and government service income. Additionally, it examines how the “other income” provision in French tax treaties applies to income from third states. The article then considers the impact of the “other income” provision within the UN Model on French treaty practice, paying particular attention to notable deviations.