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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 from professional services or other independent activities of a similar nature shall be taxable only in that State. However, such income shall also be taxable in the other Contracting State:

  • (a) if such resident has in that other State a fixed base regularly available to him for the purposes of carrying on his activities. In such case, only that part of the income attributable to that fixed base may be taxed in that other Contracting State; or
  • (b) if the resident is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in the relevant fiscal year. In such case, only that part of the income derived from the activities performed by that resident in the other Contracting State may be taxed in that other State.

(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 and accountants.