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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 resident of a Contracting State for the provision of professional services or other independent activities shall be taxable only in that State. However, such income may also be taxed in the other Contracting State if the individual is regularly available to him in the other Contracting State, of a fixed base for the exercise of their activities, but only for the portion attributable to that fixed base.

(2) The term "professional services" includes especially independent activities of scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.