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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.

ARTICLE 14

Independent Personal Services

(1) Income derived by a resident of a Contracting State, in respect of independent personnel services or other activities of an independent nature in the other Contracting State shall be taxable only in this State. However, such income may be taxed in the other Contracting State:

  • (a) if such resident has a fixed base regularly available to him in the other Contracting State for the purpose of his activities in that other State. However, only that part of the income which is attributable to such fixed base shall be taxable in that other State; or
  • (b) if such resident stays in the other Contracting State for a period or periods amounting to or exceeding in the aggregate 183 days during any twelve-month period. In such a case, only that part of the income which is derived from activities exercised in that other State shall be taxable in that other State.

(2) The term "independent personnel services" includes in particular, scientific, literary, artistic, educative or pedagogic independent activities and independent professions such as doctors, lawyers, engineers, architects, dentists and accountants.