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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 from professional services or other independent activities of a similar nature shall be taxable only in that State unless the resident has in the other Contracting State, a fixed base regularly made available to him for the purpose of performing his or her activities. In such a case, only that part of the income which is attributable to such fixed base shall be taxable in that other State.

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