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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Other Income

(1) Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that State.

(2) However the provisions of paragraph (1) shall also apply to income derived from immovable property as defined in paragraph (2) of Article 6, if the recipient of such income, being a Contracting State, its local government or political and administrative subdivision of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this article, activities that are performed 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 7 or Article 14, as the case may be, shall apply.