background image
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, regardless of where they arise, which are not dealt with in the foregoing 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 as defined in paragraph (2) of Article (6), as long as the beneficiary of such income, being a resident of a Contracting State, carries on a business activity 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 therewith. In such case the provisions of Article 7 or Article 14 of the Convention, as the case may be, shall apply.