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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 professional services or similar activities of an independent character shall be taxable only in that State. Such income, however, shall also be taxable in the other Contracting State in the following cases:

  • (a) if the individual has or had regularly available, in the other Contracting State, a fixed base for the exercise of his profession, in such case, only that part of the income that is attributable to that fixed base shall be taxed in that other Contracting State, or
  • (b) if his stay in the other Contracting State is for a period or periods of a total length equal to or more than 183 days during any 12 month period commencing or ending in the calendar year in question, in such case, only that part of the income which is derived from activities exercised during the period in which the individual was present in the other State may be taxed in that other State.

(2) The term "professional 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.