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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 22

Other Incomes

(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) of this Article shall not apply to income from immovable property referred to in paragraph (2) of Article 6 of this Convention, 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 carries out independent personnel services through 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. In such case, the provisions of Article 7 or 14 of this Convention, shall apply.