(1) Items of income of a resident of a Contracting State,
wherever arising, other than income paid out of trusts which are
not expressly mentioned in the foregoing Articles of this
Convention shall be taxable only in that 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 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.
