Australian Tax Treaties
Items of income, not expressly mentioned in the foregoing Articles, derived from sources in one of the Contracting States by a resident of the other Contracting State may be taxed in the first-mentioned State.
(2)
Subject to the provisions of paragraph (3), income derived by a person who is a resident of one of the Contracting States from sources in that Contracting State or from sources outside both Contracting States shall be taxable only in the Contracting State of which that person is a resident.
(3)
The provisions of paragraph (2) shall not apply to income derived by a resident of one of the Contracting States where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
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