ARTICLE 21
Other Income
(1) Income that is derived by a resident of a Contracting State and was not considered in the preceding Articles of this Agreement, regardless of its origin, may be taxed in that State only.
(2) The provisions of paragraph (1) shall not apply to income, other than income from immovable property as defined in Article 6, paragraph (2), if the recipient of such income, being a resident of a Contracting State, 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 7 or Article 14, as the case may be, shall apply.