Article 21 Other income

Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.

The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect 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.

However, the provisions of this Article will not be applicable if the rights in respect of which the income is paid are created or assigned to take advantage of this Article and not for bona fide commercial reasons. In case a Contracting State intends to apply this provision, its competent authority shall in advance consult with the competent authority of the other Contracting State.