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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Independent Personal Services

(1) Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character performed in the other Contracting State shall be taxable in that other State, but the tax so charged shall not exceed 10 per cent of the gross amount received from those services or activities.

(2) The term "professional services" includes, such as technical, financial and administrative consultancy, the independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of professionals, such as physicians, lawyers, engineers, architects, dentists and accountants.