Common use of INDEPENDENT PERSONAL SERVICES Clause in Contracts

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 365 days in the calendar year concernedany 15-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the relevant calendar year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin a twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other similar activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially includes, especially, independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 365 days in the calendar year concernedany fifteen-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar calender year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes includes, especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar taxable year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedwithin a twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, physicians ,lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any twelve month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedrelevant fiscal year; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedwithin any period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedrelevant fiscal year; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstancesState. However, when such income may also be taxed in the other Contracting State:State in the following cases. (a) if he the resident has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only such case so much of the income as is attributable to that fixed base may be taxed in that the other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods equalling or exceeding in the aggregate 183 days in during the calendar year concerned; in that case, such case only so much of the income as is derived from his the activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, . when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany twelve month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the exercise of the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except State. However, in one of the following circumstances, when circumstances such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that the other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” includes especially " includes, especially, independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12 months period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching reaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting Other State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay he is present in the other Contracting Contraciting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent indenpendent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateCoctracting State : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 91 days in the calendar year concernedwithin any period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching activities as well as the he independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State:. (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; , in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him his in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a I period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, case only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or o teaching activities as well as the independent activities of o physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 91 days in the calendar year concernedany period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent indenpendent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateCoctracting State : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 91 days in the calendar year concernedwithin any period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the he independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; , in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year within 12 months concerned; in that case, only as so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; , in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 90 days in the calendar fiscal year concernedof that other State; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “" professional services” services " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State.; 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.. 818 Government Notices 1994

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State:. (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is s attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except State. However, in one of the following circumstances, when circumstances such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that the other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only case only; so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 24. The term “"professional services” includes especially " includes, especially, independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an in independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base based regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12- month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character of similar nature shall be taxable only in that Contracting State except in one of the following circumstancesState. Nevertheless, when such this income may also be taxed in the other Contracting StateState in the following two cases: (a) if he the said person has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that this case, the income may be taxed in the other State but only so much of the income it as is attributable to that fixed base may be taxed in that other Contracting State;base; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedwithin any period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. (1. ) Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany twelve month period; in that case, case only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. (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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting StateState :— (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. ‌ (1. Income ) Subject to the provisions of Article 13, income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. (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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstancesState; however, when such income may also be taxed in the other Contracting StateState in the following circumstances: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, such case only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, such case only so much of the income as is derived from his activities performed in that other Contracting State may be remuneration as is derived therefrom may be taxed in that other Contracting State. 2. The term “professional services” includes includes, especially independent scientific, literary, artistic, educational educational, or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 91 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 91 days in the calendar year concernedwithin any period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as us is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar calender year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;State ; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar relevant fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” includes especially " include independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his this activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any 12-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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, surgeons, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except State. However, in one of the following circumstances, when circumstances such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that the other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only case only; so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” includes especially " includes, especially, independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) a. if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) b. if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State:; (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his has activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedconcerned ; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of by physicians, lawyers, engineersengineers , architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State.; or 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar taxable year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;State ; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concerned; relevant fiscal year, in that case, only so much of the income income, as is derived from his activities activities, performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar taxable year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; activities : in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany consecutive twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State State, except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “''professional services” '' includes especially independent scientific, literary, artistic, educational or teaching activities as well as in the exercise of the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing perfo his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in taxe that other Contracting State;State ; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 ag 90 days in the calendar year concerned; relevant fiscal year, in that case, only so much of the income income, as is derived from his activities acti performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 91 days in the calendar year concernedwithin any period of 12 months; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. ‌ 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, circumstances when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, case only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany consecutive period of 12 months; in that case, case only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState : (a) if If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedwithin any twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) a. if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; , in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) b. if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in of that caseother State, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, ; when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedany twelve-month period; in that case, only as so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, engineers, lawyers, engineersdentists, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect from the performance of professional services or other independent activities of an independent a similar character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState : (a) if he has a fixed base based regularly available to him in the other Contracting State for the purpose of performing his activities; , in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;State ; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar fiscal year concerned; in of that caseother State, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent independent, scientific, literary, artistic, educational or teaching activities activities, as well as the independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, ; when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 90 days in the calendar year concernedany twelve- month period; in that case, only as so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “"professional services” " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, engineers, lawyers, engineersdentists, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 2. The term “professional services” includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, dentists, lawyers, engineers, architects, dentists architects and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; and (b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 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.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State except in one of the following circumstances, when such income may also be taxed in the other Contracting State: (a) if he the individual has a fixed base regularly available to him in the other Contracting State for the purpose of performing his the activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State;; or (b) if his stay the individual is present in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; in that case, only so much of the income as is derived from his the activities performed in that other Contracting State may be taxed in that other Contracting State. 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.