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Germany - Russia Tax Treaty (as amended by 2007 protocol) — Orbitax Tax Hub

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.


Income from Independent Personal Service

(1) Income derived from out of an independent personal service or from any other service of independent nature by a person resident in one Contracting State can be taxed in the other State only if the person, for the purpose of performing his activity, has a fixed base regularly available to him. Thereby only such income may be taxed that can be attributed to that fixed base.

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