Taxation of other income: residence generally has exclusive taxing right, but source may tax gambling and PE connected income.

Items of income of a resident not dealt with in other treaty provisions are taxable only in the State of residence, except where such income is effectively connected with a permanent establishment or arises from independent personal services performed from a fixed base in the other State-in which case allocation rules for business profits or independent services apply-and except that income from lotteries, gambling and similar games sourced in the other State may be taxed by that source State.

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