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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 independent activities of a similar nature shall be taxable only in that State. If the resident usually stays in the other Contracting State and operates a fixed base regularly available to him in the other Contracting State, the income derived by the resident in the other Contracting State shall be taxable only if the income is related to such fixed base.

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