Other income taxation: resident state primarily taxable; source state may tax if linked to permanent establishment or fixed base. Article 22 provides that items of income of a resident not dealt with in earlier articles are generally taxable only in the State of residence, but where such income is effectively connected with a permanent establishment or a fixed base in the other State the provisions of Article 7 or Article 14 apply, and notwithstanding these provisions the other Contracting State may also tax items of a resident's income arising in its territory that are not addressed elsewhere in the Convention.