1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention or Article 22 shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in Paragraph 2 of Article 6 (Income from Real Property), if the beneficial owner of the 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 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.
