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 14
Independent Personal Services
(1) Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State. Such income, however, shall be taxable in the other Contracting State in the following cases:
- (a) if the person concerned has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in the other Contracting State, or
- (b) if his stay in the other Contracting State for the purpose of performing that activity extends for a period or periods equal to or more than 183 days in the fiscal year; in this case, only the portion of the income that is attributable to the said activity may be taxed in the other Contracting State.
(2) The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists, and accountants.