background image
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 activities of an independent character shall be taxable only in that State unless such a person has, in the other Contracting State a fixed base for the conduct of his business or if he is present in that other State for a period or periods lasting a total of more than 183 days in a 12 month period. If he has a fixed base or is present in that other State during the aforesaid period or periods, the income may be taxed in that other State but only that part of the income which is attributable to this fixed base or derived from that other State for the aforesaid period or periods.

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