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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) The income that a resident of a Contracting State draws from personal services or other independent personal services of similar nature are taxable only in this State, unless such resident does not have in the other Contracting State a fixed base for performing his activities. If he has such a base, the incomes shall be taxable in the other State, but only insofar as they are attributable to the aforementioned fixed base.

(2) The term "personal services" includes in particular independent activities of scientific, literary, artistic, educational or teaching nature, as well as independent activities of doctors, lawyers, engineers, architects, dentists and accountants.