DT10722 - Japan: double taxation agreement, Article 23: Income not expressly mentioned

This agreement applies for periods before the new comprehensive agreement has effect (see DT10650).

1. Items of income of a resident of a Contracting State, wherever arising other than income paid out of trusts, which are not dealt with in the foregoing Articles of this Convention shall be taxable only in that Contracting State.
   
   
2. The provisions of paragraph (1) of this Article shall not apply to income, other than income from immovable property as defined in paragraph (2) of Article 7, 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 Contracting 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 a case the provisions of Article 8 or Article 15, as the case may be. shall apply.