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

  • (a) in case this resident habitually has, in that other State, a fixed base for the exercise of his or her activities; in this case, only that part of the income which is attributable to this fixed base shall be taxable;
  • (b) if the resident remains in the other Contracting State for carrying out business for a period exceeding a total of 183 days during a period of 12 months.

(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 and accountants.