ARTICLE VII
Article 22 (Other Income) of the Convention shall be deleted and replaced by
the following:
“Article 22
Other Income
1. Items of income beneficially owned by a resident of a Contracting
State, wherever arising, not dealt with in the foregoing Articles of this
Convention shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than
income from real property as defined in paragraph 2 of Article 6 (Income
From Real Property), if the beneficial owner of such income, being a
resident of a Contracting State, carries on 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 attributable to such permanent establishment or fixed
base. In such case the provisions of Article 7 (Business Profits) or Article
14 (Independent Personal Services), as the case may be, shall apply.”