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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.



(1) The income generated by a resident of a Contracting State from independent professions or other similar independent activities shall be taxable only in such State except for the following cases, where such income may also be taxable in the other Contracting State:

  • (a) If he/she regularly operates a fixed centre in the other Contracting State, the income generated thereby shall be taxed in the other Contracting State only by the proportion attributable to such fixed center.
  • (b) If he/she visits the other Contracting State for a period or periods that reach or exceed 183 days in aggregate period of twelve-months that starts or ends in the fiscal year concerned.

In such case, the income of such activities made in the other State may be taxable in such State.

(2) The term "independent professions" shall include in particular the scientific, literary, artistic or educational independent activities as well as the independent activities related to physicians, lawyers, engineers, architectures, dentists and accountants.