Taxation of other income: residence state primary, but permanent establishment links can permit source-state taxation.

Income of a resident not dealt with elsewhere in the Convention is generally taxable only in the State of residence, except where such income (other than immovable property income) is effectively connected with a permanent establishment or fixed base in the other State-in which case Articles 7 or 15 apply-and notwithstanding those provisions the other State may tax items of resident income arising there.

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