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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 Incomes

(1) The items of the income of a resident of a Contracting State, wherever they may arise, which are not dealt in the preceding Articles of this Convention are taxable only in this State.

(2) The provisions of paragraph (1) shall not apply to the income, other than the income arising from immovable property if the recipient of this income, being the resident of a Contracting State, carries on a business in the other Contracting State, through a permanent establishment situated therein, and the right or property for which the income is paid is effectively connected with the permanent establishment or fixed base. In this case, the provisions of Article 7, as the case may be, are applicable.