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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.


Provision of Services

(1) Income derived by a person who is a resident of a Contracting State, from the provision of services performed in the other Contracting State, may be liable to be taxed in the first-mentioned State.

(2) However, such provision of services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but the tax so charged shall not exceed 10 percent of the gross amount received for such services, unless the person obtaining the income has a permanent establishment available to him in that Contracting State for the purpose of performing his activities. In this last-mentioned case, such income shall be liable to be taxed in that State in accordance with the provisions of Article 7 of this Convention.

(3) The terms "provision of services" as used in this Article, includes services of a technical, legal, economic, financial, and administrative nature, or other similar ones, including consulting services.