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
Items of income of a resident of a Contracting State not expressly mentioned in the foregoing Articles of this Convention shall not be taxable in that State unless they belong to a permanent establishment or a fixed base situated in the other Contracting State.