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ARTICLE 23
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Other Income
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1. Subject to the provisions of paragraph 2, items of income
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of a resident of a Contracting state, wherever arising, which are
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not expressly dealt with in the foregoing Articles of this
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Convention shall be taxable only in that Contracting state.
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2. The provisions of paragraph 1 shall not apply to income,
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other than income from immovable property as defined in paragraph
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2 of Article 6 (Income from Immovable Property (Real Property)),
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if the beneficial owner of the income, being a resident of a
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Contracting state, carries on business in the other Contracting
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state through a permanent establishment situated therein, or
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performs in that other state independent personal services from a
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fixed base situated therein, and the income is attributable to
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such permanent establishment or fixed base. In such case the
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provisions of Article 7 (Business Profits) or Article 15
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(Independent Personal Services), as the case may be, shall apply.
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3. Notwithstanding the provisions of paragraphs 1 and 2,
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items of income of a resident of a Contracting state not dealt
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with in the foregoing articles of this Convention and arising in
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the other Contracting state may also be taxed in that other
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State