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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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 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 also be taxable in the other Member States in the following cases:

  • (a) In case the concerned person habitually has, in the other Member States, a fixed base for the exercise of his or her activities; in this case, only that part of the income which is attributable to this fixed base shall be taxable in the other Member States; or
  • (b) if his stay in the other Member States extends for a period or periods totaling or exceeding 183 days during the tax year.

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