Document ID: chunk:federal_register_of_legislation:C2008A00102:schedule:6:p22
Version: federal_register_of_legislation:C2008A00102
Segment Type: schedule
Provision Reference: sch 6 (pt 22/39)
Character Range: 55559–58262

that person's education or training receives for the purpose of that person's maintenance, education or training shall not be taxed in the first‑mentioned Contracting State, provided that such payments arise from sources outside that first‑mentioned Contracting State.  The exemption provided by this Article shall apply to a business apprentice only for a period not exceeding one year from the date the person first begins that person's training in the first‑mentioned Contracting State.

Article 20

SLEEPING PARTNERSHIP (TOKUMEI KUMIAI)

Notwithstanding any other provisions of this Convention, other than those of Article 26, any income, profits or gains derived by a sleeping partner in respect of a sleeping partnership (Tokumei Kumiai) contract or other similar contract may be taxed in the Contracting State in which such income, profits or gains arise, and according to the laws of that Contracting 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 Contracting State.

2.  The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6, derived by a resident of a Contracting State who carries on business in the other Contracting State through a permanent establishment situated therein and the property or right 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.

3.  Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention from sources in the other Contracting State may also be taxed in that other Contracting State.

Article 22

SOURCE OF INCOME

1.  Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8 and 10 to 18, may be taxed in the other Contracting State shall for the purposes of the law of that other Contracting State relating to its tax be deemed to arise from sources in that other Contracting State.

2.  Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8, 10 to 18 and 20, may be taxed in the other Contracting State shall for the purposes of Article 25 and of the law of the first‑mentioned Contracting State relating to its tax be deemed to arise from sources in the other Contracting State.

Article 23

LIMITATION ON BENEFITS

1.  Except as otherwise provided in this Article, a resident of a Contracting