ARTICLE 14

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 unless such services are performed in the other Contracting State and he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. In such case, the income may be taxed in the other State, but only so much of it as is attributable to that fixed base. For this purpose, where an individual who is a resident of a

Contracting State stays in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the taxable year concerned, he shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to in the first sentence of this paragraph shall be attributable to that fixed base.

2. For the purposes of paragraph 1, the income that is taxable in the other Contracting State shall be determined in the same way as income of a resident of that other State derived in respect of professional services or other activities of an independent character. However, nothing in this paragraph shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities that it grants to its own residents.

3. 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.