- 1
- Subject to the provisions of paragraph 2, items of income of a resident of one of the States, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
- 2
- However, if such income is derived by a resident of one of the States from sources in the other State, such income may also be taxed in the State in which it arises, and according to the law of that State, but the tax so charged shall not exceed 25 per cent of the gross amount of such income.