Taxation of other income: residence-based rule with source taxation for gambling and PE-connected income; exceptions apply. Article 22 provides that residual items of income of a resident not otherwise dealt with are taxable only in the State of residence, except that income (other than immovable property) effectively connected with a permanent establishment or arising from independent personal services from a fixed base in the other State is governed by the business profits or independent personal services provisions, and income from lotteries, gambling and similar games sourced in the other State may be taxed in that source State.