background image
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 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 such resident has in that other State a fixed base regularly available to him for the purpose of carrying on his activities. In such case, only that part of the income received from the exercise of such activities shall be taxable in that other State; or
  • (b) if the resident is present in the other Contracting State for a period or periods amounting to or exceeding in the aggregate 183 days and any twelve-month period beginning or ending in the relevant fiscal year. In such case the income from the activity exercised in the other Contracting Parties shall be taxable only 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, architects, surgeons, dentists and accountants.