ARTICLE 20

STUDENTS

Payments which a student or business apprentice who is or was immediately

before visiting a Contracting State a resident of the other Contracting State and who is

present in the first-mentioned State solely for the purpose of his education or training

receives for the purpose of his maintenance, education or training shall not be taxed in

that State, provided that such payments arise from sources outside that State.

ARTICLE 21

OTHER INCOME

1. Items of income of a resident of a Contracting State, wherever arising, not dealt

with in the foregoing Articles of this Convention shall be taxable only in that State.

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 of this Convention, 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 per-

forms 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.

3. Notwithstanding the provisions of paragraphs 1 and 2, items of income derived

by an individual who is a resident of a Contracting State from gambling and lotteries and arising in the other Contracting State may be taxed in that other Sta

te.

4. Where, by reason of a special relationship between the person referred to in

paragraph 1 and some other person, or between both of them and some third person, the

amount of the income referred to in paragraph 1 exceeds the amount (if any) which

would have been agreed upon between them in the absence of such a relationship, the

provisions of this Article shall apply only to the last mentioned amount. In such a case,

the excess part of the income shall remain taxable according to the laws of each Con-

tracting State, due regard being had to the other applicable provisions of this Conven-

tion.

ARTICLE 22

CAPITAL

1. Capital represented by immovable property referred to in Article 6 of this Con-

vention, owned by a resident of a Contracting State and situated in the other Contracting

State, may be taxed in that other State.

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