ARTICLE 14
Independent Personal Services
(1) Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar character shall be taxable only in that State unless such services or such activities are performed in the other Contracting State. If the services or the activities are so performed, such income as is derived therefrom may be taxed in that other State.
(2) Notwithstanding the provisions of paragraph (1), income derived by a resident of a Contracting State in respect of such services or such activities performed in the other Contracting State shall be taxable only in the first-mentioned State if he is present in that other State for the purpose of performing his services or activities for a period or periods not exceeding in the aggregate 30 days in the calendar year concerned.
(3) 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.
(4) The provisions of paragraph (1) shall also apply to payments made by an enterprise of a Contracting State to an enterprise of the other Contracting State for the provision of professional and technical services, provided that such payments are not attributable to a permanent establishment which the last-mentioned enterprise has in the other State. However, the tax charged in the first-mentioned State shall not exceed 5 per cent of the gross amount of such payments attributable to the services performed in that State.