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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 of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that State.

(2) The provisions of paragraph (1) shall not apply to income other than income from immovable property, as defined in paragraph (2) of Article 6, where the recipient of such income, resident of a Contracting State, in the other Contracting State means an industrial or commercial activity through a permanent establishment located therein or a liberal profession by means of a fixed base which is located therein, and that the right or the property generating the income actually relates to it. In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply.