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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 to perform a profession or other activities of an independent character shall be taxable only in that State, unless this resident has, as usual, in the other Contracting State, a fixed base for the performance of his activities. In the latter case, the income may be taxed in the other Contracting State, but only in so far as they are attributable to that fixed base.

(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.