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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 Income

(1) 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) above shall not apply to income, other than income derived from immovable property as defined in paragraph (2) of Article 6, if the beneficial owner of such income, being a resident of a Contracting State, carries on an industrial or commercial activity in the other Contracting State through a permanent establishment situated therein, or performs independent personal services from a fixed place of business situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed place of business. In this case, such elements of income may be taxed in that other Contracting State according to its domestic laws.