Other income under DTAA: residence-state taxation general rule, source-state taxation allowed if effectively connected to a permanent establishment. Income of a resident not addressed in other Articles is generally taxable only in the State of residence, except where the recipient's income-producing rights are effectively connected with a permanent establishment or fixed base in the other State-in which case the rules on business profits or independent personal services apply-and, notwithstanding those provisions, such income arising in the source State may also be taxed by that State.