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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) Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other independent activities of a similar character shall be taxable only in that State unless he is present in the other Contracting State for a period or periods amounting to or exceeding in the aggregate 90 days in the relevant fiscal year: in that case, such income may also be taxed in that other State, but only so much of it as is derived from his activities performed in that other State.

(2) The term "professional services" include especially independent personal services of an individual in his capacity as a physician, teacher, architect, engineer and accountant.