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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 15

Independent Personal Services

(1) Income derived by a resident of one of the States in respect of professional services or other independent activities of a similar character shall be taxable only in that State unless he has fixed base available to him in the other State for the purpose of performing his activities. If he has such a fixed base available to him, the income may be taxed in that other State but only so much of it as is attributable to that fixed base.

(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.