ARTICLE 22
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 in that State regardless of the origin.
(2) The provisions of paragraph (1) of this Article shall not apply to income other than income derived from immovable property referred to in paragraph (2) of Article 6, provided that the beneficiary of such 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) Where, by reason of a special relationship either between a resident of a Contracting State and a resident of the other Contracting State or between both of them and some other person, the amount of income referred to in paragraph (1) of this Article exceeds the amount which would have been agreed upon by the payer and the recipient of the income in the absence of such special relationship, then the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the domestic laws of each Contracting State, due regard being had to the other provisions of this Convention.