Independent Personal Services
(1) Notwithstanding the provisions of the Article 12 relating to fees for technical services, 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 Contracting State except in the following circumstances:
- (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; or
- (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the relevant fiscal year;
in such case, only so much of the income as is attributable to that fixed base or as is derived from his activities performed in that other Contracting State, as the case may be, may also be taxed in that other Contracting State.
(2) The term "professional services" includes independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.