(1) Items of income of a resident of a Contracting State‚ wherever arising‚ not dealt with
in the foregoing Articles of this Agreement shall be taxable only in that State.
(2) The provisions of paragraph 1 shall not apply to income‚ other than income from
immovable property‚ if the recipient of such income‚ being a resident of a Contracting
State‚ carries on business in the other Contracting State through a permanent
establishment 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 shall apply.