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Article 14 INCOME FROM INDEPENDENT PERSONAL SERVICES

Article 14
INCOME FROM INDEPENDENT PERSONAL SERVICES

 

1. Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other activities of an independent character shall be taxable only in that State except in following circumstances when such income may also be taxed in the other Contracting State, but only so much of the income as is derived from his activities performed in that other State:

a) if he has a fixed base regularly available to him in the other State for the purpose of performing his activities; or

b) if he is present in the other State for a period or periods exceeding in the aggregate 90 days in any twelve-month period.

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, accountants and auditors.