Common use of INDEPENDENT PERSONAL SERVICES Clause in Contracts

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting Party in respect of professional services or other activities of an independent character shall be taxable only in that Party except in the following circumstances, when such income may also be taxed in the other Contracting Party: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 Party; or (b) if his stay in the other Contracting Party is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period concerned; in that case, only so much of the income as is derived from his activities performed in that other Party may be taxed in that other Party. 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 Party in respect of professional services or other activities of an independent character shall be taxable only in that Party except in the following circumstances, when such income may also be taxed in the other Contracting Party: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 Party; or (b) if his stay in the other Contracting Party is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party may be taxed in that other Party. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting Party:State; (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting Party:State (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party Contracting State except in the following circumstances, circumstances when such income may also be taxed in the other Contracting Party: (a) State: if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) or if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve 12-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party Contracting State may be taxed in that other PartyContracting 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting Party:State (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve- month period commencing or ending in the taxable period year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve- month period commencing or ending in the taxable period calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting Party:State (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “"professional services” " includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party except in the following circumstancesContracting State. However, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay he is present in the other Contracting Party is State for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his the activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities similar services of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 auditors and accountants.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by a resident of a Contracting Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting Party:State (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve- month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve- month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party except State. However in the following circumstances, when circumstances such income may also be he taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay he is present in the other Contracting Party is State for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period concernedor the fiscal year, as the case may be, of that State; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party Contracting State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve within [any] twelve-month period commencing or ending in the taxable period concernedperiod; in that case, case only so much of the income as is derived from form his activities performed in that other Party Contracting State may be taxed in that other PartyContracting 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 Party in respect of professional services or other activities of an independent character shall be taxable only in that Party except in the following circumstances, when such income may also be taxed in the other Contracting Party: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 Party; or (b) if his stay in the other Contracting Party is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party may be taxed in that other Party. 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. Note 16: There have been no changes to this Article as the MLI has no impact on it.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting Party State in respect of professional services or other activities similar services of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve 12-month period commencing or ending in the taxable period calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 Party State in respect of professional services or other activities of an independent character shall be taxable only in that Party State, except in the following circumstances, circumstances when such income may also be taxed in the other Contracting PartyState: (a) if If he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if If his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the taxable period fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 2. The term “professional services” includes especially includes, especially, independent scientific, literary, artistic, educational or teaching activities 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 Party State in respect of professional services or other activities similar services of an independent character shall be taxable only in that Party State except in the following circumstances, when such income may also be taxed in the other Contracting PartyState: (a) if he has a fixed base regularly available to him in the other Contracting Party 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 PartyState; or (b) if his stay in the other Contracting Party State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the taxable period calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Party State may be taxed in that other PartyState. 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 auditors and accountants.

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