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.
ARTICLE 12
INDEPENDENT PERSONAL SERVICES
*(1) Income from the performance of professional services and all earned income other than that referred to in Articles 13, 13B or 14 shall be taxable only in the Contracting State in which the personal services from which the income is derived are performed.
*(2) A profession shall be deemed to be exercised in one of the Contracting States only where the taxpayer uses for his activity a fixed base regularly available to him in that State.
(3) Article 4, paragraph (4) shall apply mutatis mutandis.