Taxation of other income: residence principle governs, with permanent establishment and fixed base exceptions permitting source taxation.

Unspecified items of income of a resident are generally taxable only in the State of residence. Exceptions apply where the resident carries on business through a permanent establishment or performs independent personal services from a fixed base in the other State and the income is effectively connected with that establishment or base, in which case the provisions on business profits or independent personal services govern. Additionally, the source State may also tax such unspecified items arising in its territory.

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