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 21
Income not Expressly Mentioned
(1) Any income of a resident of a Contracting State which is not expressly mentioned in the foregoing Articles of this Convention shall be taxable only in that State.
(2) The provisions of Article 13, paragraph (5), second sentence, shall apply mutatis mutandis to income derived from third States.