Taxation of other income: residence principle subject to permanent establishment and fixed-base connection allowing source-state taxation. Items of income of a resident not otherwise dealt with in the Convention are taxable only in the State of residence, except where income (other than immovable property) is effectively connected with a permanent establishment or fixed base in the other State; in that case provisions governing business profits or independent personal services apply, and items of income arising in the other State may be taxed there.