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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 from rendering professional services or other activities of an independent nature, shall be taxed only in that State except for the following cases:

  • (a) if he/she regularly operates a fixed base in the other Contracting state, the income generated by the centre shall be taxed in such state;
  • (b) if he/she visits the other Contracting state for a period not less than 183 days in aggregate, the income of such activities made in the other Contracting state may be taxable in such state;

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