ARTICLE 14
Independent Personal Services
(1) Income derived by a resident of a Contracting State from professional services or other independent activities of a similar nature shall be taxable only in that State except in cases where such resident has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, then the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. If the person is resident in the other Contracting State for a period or periods exceeding in the aggregate 183 days during any twelve-month period beginning or ending during the course of fiscal year, then that individual shall be deemed, to be a person having a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; the profits from the above mentioned activities, carried on in the other Contracting State, may be attributable to that fixed base. In such case, the profits derived from such activity may be taxed according to the provisions of Article 7 that concern the attribution of profits from a business enterprise.
(2) The term "professional services" includes in particular independent scientific, literary, educational or teaching activities, as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.