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
Other Income
(1) Income of a person resident in a Contracting State that were not treated in the Articles above can only be taxed in this State, regardless of their origin.
(2) Paragraph (1) of this Article does not apply to income as such from immoveable property in the sense of Article 6 Paragraph (2), if the recipient resident in one Contracting State exercises a business activity in the other Contracting State through a permanent establishment located there and the rights or property for which these income are paid actually belong to this permanent establishment. In this case Article 7 shall apply.