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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in the following circumstances, 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 183 270 days in the fiscal year concernedany 12-month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 State except in the following circumstances, 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 fiscal 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 State may be taxed in that 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 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 an individual who is resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in 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 fiscal 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 State may be taxed in that 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 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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) If 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 territory in respect of professional services or other activities of an independent character shall be taxable only in that State territory except in the following circumstances, when such income may also be taxed in the other Contracting Stateterritory: a) If if he has a fixed base regularly available to him in the other Contracting State territory 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 Stateterritory; or b) If if his stay in the other Contracting State territory is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that the other State territory may be taxed in that Stateterritory. (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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 an individual who is resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that State except State. However, in 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 is 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State. (2) . The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of or 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 State except in one of the following circumstances, when such income may also be taxed in the other Contracting StateState if: a1) 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; b2) 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in the following circumstances, when where such income may also be taxed in the other Contracting State: a) If 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 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that State. (2) . The term "professional services" includes included especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physiciansphysician, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. (1) . Income derived by 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 State except in the following circumstances, 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 fiscal year concernedrelevant "taxable year"; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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 State except in the following circumstancesContracting State; 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, only such case 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 fiscal 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 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 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 his stay if he is present in the that other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal 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 State may be taxed in that 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, engineersen0gineers, 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 State except in 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that Contracting State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State:State:- a) If 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 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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 a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in the following circumstances, 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 90 days in the fiscal year concernedwithin any twelve month period; in that case, only so much of the income as is derived from his activities performed in that the other State may be taxed in that 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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that State except in the following circumstances, 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 StateState ; 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists dentists, accountants and accountantsother such professions.

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 State except State. However, in 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 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal year concerned; any twelve-month period, in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 State except in the following circumstances, 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 relevant fiscal year concerned; in that caseyear, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. (1) . Income derived by 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 State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If 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 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 fiscal year concerneda period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal year concernedany twelve-month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that Contracting State except in the following circumstances, 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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 State except in the one 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that State except in the following circumstances, 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; 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, 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 State except in the following circumstances, 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 activitiesactivities ; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting StateState ; 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists dentists, accountants and accountantsother such professions.

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 State except in 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 case 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 fiscal year concerned; in that case, only case so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If 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 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 relevant fiscal year concerned; in that caseyear, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. (1) . Income derived by 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 State except in the following circumstances, 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 fiscal year concerneda period of twelve months; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If a. 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 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 relevant fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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 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 fiscal year concernedany twelve month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 State except in the following circumstancesContracting State. However, 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; the activities; in that case, only so much of the income as is attributable at ributable to that fixed base may be taxed in that the other Contracting State; orState; b) If his stay if he is present in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal year concerned; any twelve month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that State. (2) . The term "professional services" includes especially especia ly independent scientific, literary, artistic, educational or teaching activities as well we l as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. (1) . Income derived by a an individual who is resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 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 fiscal calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, technicians, architects, dentists and accountants.

INDEPENDENT PERSONAL SERVICES. (1) . Income derived by 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 State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If 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 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 fiscal relevant " taxable year concerned"; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State. (2) . The term "" professional servicesservices " 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 independent activities of an independent a similar character shall be taxable only in that Contracting State except in the following circumstances, 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State. (2) The . 2 the term "professional services" ―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 State except in 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 fiscal year concernedwithin any twelve-month period; in that case, case only so much of the income as is derived from his activities performed in that the other State may be taxed in that 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 State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If 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 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists dentists, accountants and accountantsother such professions.

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 State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting State: a) If 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 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other 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 territory in respect of professional services or other activities of an independent character shall be taxable only in that State territory except in the following circumstances, when such income may also be taxed in the other Contracting Stateterritory: (a) If if he has a fixed base regularly available to him in the other Contracting State territory 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 Stateterritory; or (b) If if his stay in the other Contracting State territory is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State territory may be taxed in that Stateother territory. (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 State except in 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 fiscal year concernedany twelve month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 independent activities of an independent a similar character shall be taxable only in that State except in the following circumstances, 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 relevant fiscal year concernedyear; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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, surgeons, lawyers, engineers, architects, dentists dentists, accountants and accountantsother such professions.

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 State except in the following circumstances, 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 fiscal year concernedany twelve month period; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that 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 State except in 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 90 days in the fiscal 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 State may be taxed in that 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.