Taxation of other income: residence-based taxation except where effectively connected with a permanent establishment or fixed base. Article 22 provides that items of other income of a resident are taxable only in the State of residence, except where such income (excluding immovable property income) is effectively connected with a permanent establishment or a fixed base in the other Contracting State, in which case the rules on business profits or independent personal services apply; separately, income from lotteries, races, games and other gambling sourced in the other State may be taxed by that source State.