第21条 その他の所得
令和7年11月21日|p.24
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ARTICLE 21
OTHER INCOME
1. Items of income beneficially owned by a resident of a Contracting State, wherever
arising, not dealt with in the foregoing Articles of this Convention shall be taxable only
in that Contracting State.
7.
2. The provisions of paragraph 1 shall not apply to income, other than income from
immovable property as defined in paragraph 2 of Article 6, if the beneficial owner of such
income, being a resident of a Contracting State, carries on business in the other
Contracting State through a permanent establishment situated therein and the right or
property in respect of which the income is paid is effectively connected with such
permanent establishment. In such case the provisions of Article 7 shall apply.