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HMRC internal manual

Double Taxation Relief Manual

DT: Yugoslavia: double taxation agreement, Article 21: Income not expressly mentioned

(1) Items of income of a resident of a Contracting State, wherever arising, being income of a class or from sources not expressly mentioned in the foregoing Articles of this Convention shall be taxable only in that State.

(2) The provisions of paragraph (1) of this Article shall not apply if the recipient of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein or performs 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 that permanent establishment or fixed base. In such a case the provisions of Article 7, Article 14 or Article 17, as the case may be, shall apply.