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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) Items of income derived from research carried on by a resident of a Contracting State, not dealt with in the preceding Articles of this Convention shall be taxable only in that Contracting State.

(2) The provisions of paragraph (1) shall not apply to income other than income from immovable property referred to in paragraph (2) of Article 6, provided that the beneficial owner of such income, being a resident of a Contracting State, performs business in the other Contracting State through a permanent establishment situated therein, or performs in that other State 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, as the case may be, shall apply.