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Cape Verde - Sao Tome Tax Treaty (2019, not yet in force) — Orbitax Tax Hub

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 States in respect of professional services or other activities of an independent nature shall be taxable only in that State. However, such income may also be taxed in the other Contracting State:

  • (a) if the individual has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base; or
  • (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in any 12-months period commencing or ending in the fiscal year concerned, only as much of the income as is derived from his activity performed in that other Contracting State may be taxed in that other State;

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