Taxation of other income: residence based rule with exceptions for permanent establishment or fixed base permitting source taxation. Income of a resident not dealt with elsewhere in the Convention is generally taxable only in the State of residence; however, where such income (other than immovable property income) is effectively connected with a permanent establishment or a fixed base in the other State, the rules on business profits or independent personal services apply, and notwithstanding those provisions such income arising in the other State may also be taxed by that State.