Other income

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..... arising, which are not expressly dealt with in the foregoing articles of this Agreement, shall be taxable only in that ContractingState. 2. The provisions of paragraph (1) shall not apply to income .....

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..... 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. - - stat .....

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