Taxation of other income: residents taxed in their state unless income is effectively connected to a foreign permanent establishment.

Other income of a resident not dealt with elsewhere is generally taxable only in the State of residence. However, if the resident carries on business in the other Contracting State through a permanent establishment, or performs independent personal services from a fixed base there, and the right or property producing the income is effectively connected with that permanent establishment or fixed base, the provisions allocating business profits or independent personal service income apply.

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