ARTICLE 23
Other Income
(1) Items of income of a resident of a Contracting State, which are not expressly mentioned in the foregoing Articles of this Agreement, shall be taxable only in that State.
(2) The provisions of paragraph (1) of this article shall not apply to income derived by a resident of a Contracting State if this resident, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 8 or Article 15, as the case may be, shall apply.