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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.

ARTICLE 22

Other Income

(1) Items of income of a resident in a Contracting State not covered by the previous articles hereof shall be taxable in such Contracting State.

(2) The provisions of paragraph (1) herein shall not apply to the income if the receiver of such income is a resident in a Contracting State and carries out business in the other Contracting State through a permanent establishment located therein, or performs independent personal services in that Contracting State through a fixed base and if the right or property for which this income is paid is actually connected to such permanent establishment or fixed base; hence, the provisions of Article 8 or Article 15 herein shall be applied as requires.