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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.

ARTICLE 21

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 only in that State.

(2) The provisions of paragraph (1) shall not apply to income from immovable property referred to in paragraph (2) of Article 6, provided that the recipient such income, being a resident of a Contracting State, performs a business in the other Contracting State through a permanent establishment situated therein or performs 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 with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14 of this Convention, shall apply.