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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 preceding Articles of this Convention shall be taxable only in that State.

(2) The provisions of paragraph (1) of this Article shall not apply to income, other than income from immovable property provided that the beneficial owner of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 or Article 14 shall apply.

(3) Notwithstanding the provisions of paragraph (1) and (2) of this Article, items of income of a resident in a Contracting State received from gambling, including lottery or other monetary profits of a similar nature, in the other Contracting State, shall only be taxable in the other Contracting State.