Article 22 - Other income

Taxation of other income: residence generally has primary taxing right, except where effective connection with a permanent establishment shifts allocation.

Under the treaty, items of a resident's income not covered elsewhere are taxable only in the State of residence, except where such income arising in the other State is effectively connected with a permanent establishment or fixed base used for business or independent personal services, in which case rules on business profits or independent personal services apply; additionally the source State retains power to tax resident's income arising in its territory where not otherwise dealt with in the Convention.