Article 20. OTHER INCOME

This Article provides the rules for the taxation of items of income derived by a resident of a Contracting State and arising in the other Contracting State that are not dealt with in the other articles of the Convention. Such income includes lottery winnings, punitive damages, and cancellation of indebtedness income. Such income may be taxed in the State in which it arises. Income arising in a third State is not dealt with in this Article. Thus, domestic laws apply, unless the income constitutes business profits of a permanent establishment or fixed base of a resident of the other Contracting State, in which case Article 6 (Business Profits) or 14 (Independent Personal Services) applies.