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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 a resident of a Contracting State, in respect of personal services or other activities of an independent nature, may be taxed in the other Contracting State. However, where such resident has a fixed place of business regularly available to him in the other Contracting State for the purpose of performing his activities, then such income shall be taxable in the other State in accordance with its domestic laws, but only to the extent that such income is attributed to the aforementioned fixed place of business.

(2) The term "independent personal 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.