Other income

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....cting State, wherever arising, which are not expressly dealt with in the foregoing Articles of this Convention, shall be taxable only in that State. 2. The provisions of paragraph 1 shall not apply....

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....spect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. ....