Common use of INDEPENDENT PERSONAL SERVICES Clause in Contracts

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has or had a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeprovision, 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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. If he has In such a fixed basecase, the income may be taxed in the other Contracting State 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 fiscal 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 above that are performed in that other State the first sentence of this paragraph shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-twelve month period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base (fixed place regularly available to him in the other Contracting State for the purpose of performing his activities) in the other Contracting State. If he has such a fixed base, the income may be taxed in the other Contracting 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-twelve month period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State unless except in the following circumstances when such income may also be taxed in the other Contracting State: if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base; in that case, the income may be taxed in the other Contracting State but only so much of it the income as is attributable to that fixed base. For this purpose, where an individual who is a resident of a base may be taxed in that other Contracting State stays State; or if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve12-month period commencing or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him ; in that other State and case, only so much of the income that as is derived from his activities referred to above that are performed in that other Contracting State shall may be attributable to taxed in that fixed baseother Contracting State.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services sevices or other activities of an independent indenpendent character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 120 days in any twelve-month period commencing Commencing or ending in the fiscal 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 above that are performed performed. in that other State shall be attributable to that fixed base.

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 he has a fixed base is regularly available to him the individual in the other Contracting State for the purpose of performing his the individual’s activities. If he has such a fixed basebase is available to the individual, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-12 month period commencing or ending in the fiscal year concernedof income or year of assessment of that other State, he the individual shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his the individual’s activities referred to above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base is regularly available to him the individual in the other Contracting State for the purpose of performing his the individual’s activities. If he has such a fixed basebase is available to the individual, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purpose, Convention‚ where an individual who is a resident of a Contracting State stays is present 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 fiscal year concerned, he a fixed base shall be deemed to have a fixed base be regularly available to him in that other State to the individual and the income that is derived from his the individual’s activities referred to above that are performed in that other Contracting State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 120 days in any twelve-month period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base is regularly available to him that resident in the other Contracting State for the purpose of performing his the resident’s services or activities. If he has such a fixed basebase is available to the resident, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present 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 fiscal year concerned, he the resident shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his the services or activities referred to above envisaged in this Article that are performed in that other State shall be attributable to that fixed base.

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 he has or had a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other Contracting 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-twelve month period commencing or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him in that other Contracting State and the income that is derived from his activities referred to above that are performed in that other Contracting State shall be attributable to that fixed base.

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 he has or had a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he or she has a fixed base regularly available to him or her in the other Contracting State for the purpose of performing his or her activities. If he or she has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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-twelve- month period commencing or ending in the fiscal year of assessment concerned, he or she shall be deemed to have a fixed base regularly available to him or her in that other State and the income that is derived from his or her activities referred to above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For this purpose, where If an individual who is a resident of a Contracting State has no such fixed base, but he 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 fiscal 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 above that are performed in that other State shall be attributable to that deemed fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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 twelve -month period commencing or ending in the fiscal year concernedconce rned, 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has or had a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeprovision, where an individual who is a resident of a Contracting State stays is present 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 fiscal tax 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 the aforementioned services or activities referred to above that are performed in that other State during such period or periods shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 120 days in any twelve-twelve- month period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For this purpose, where If an individual who is a resident of a Contracting State has no such fixed base, but he 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 fiscal 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 above that are performed in that other State shall be attributable to that deemed fixed base.

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. If he has In such a fixed basecase, the income may be taxed in the other Contracting State 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 [*42] 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 fiscal 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 above that are performed in that other State the first sentence of this paragraph shall be attributable to that fixed base.base.‌‌‌‌‌‌‌‌‌‌

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 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. If he has such a fixed base; in that case, the income may be taxed in the other Contracting State but only so much of it the income as is attributable to that fixed base. For this purpose, where an individual who is a resident of a base may be taxed in that other Contracting State stays 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 any twelve-month period commencing or ending in the fiscal year concerned, he shall be deemed to have a fixed base regularly available to him ; in that other State and case, only so much of the income that as is derived from his activities referred to above that are performed in that other State shall may be attributable to taxed in that fixed baseState.

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 he has a fixed base regularly available to him in any of the other Contracting State States for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purpose of this purposeprovision, where an individual who is a resident of a Contracting State States stays in any of the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-twelve- month period commencing or ending in the fiscal year concernedconcerned or was present in that other State in the fiscal year concerned and in each of the two preceding years for periods exceeding in aggregate more than 122 days in each such year, 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 above that are performed in that other State shall be attributable attributed to that fixed base.

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 State, unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly regularly-available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but Statebut 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. 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 he has a fixed base is regularly available to him the individual in the other Contracting State for the purpose of performing his the individual’s activities. If he has such a fixed basebase is available to the individual, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-12 month period commencing or ending in the fiscal year concernedof income or year of assessment of that other State, he the individual shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his the individual’s activities referred to above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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 months period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he or she has a fixed base regularly available to him or her in the other Contracting State for the purpose of performing his or her activities. If he or she has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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 twelve -month period commencing or ending in the fiscal year of assessment concerned, he or she shall be deemed to have a fixed base regularly available to him or her in that other State and the income that is derived from his or her activities referred to above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base based regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. 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 he has a fixed base is regularly available to him the individual in the other Contracting State for the purpose of performing his the individual's activities. If he has such a fixed basebase is available to the individual, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-12 month period commencing or ending in the fiscal year concernedof income or year of assessment of that other State, he the individual shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his the individual's activities referred to above that are performed in that other State shall be attributable to that fixed base.

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 State, unless he has a fixed base regularly available to him in the other Contracting Contacting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base is regularly available to him the individual in the other Contracting State for the purpose of performing his the individual’s activities. If he has such a fixed basebase is available to the individual, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeConvention, where an individual who is a resident of a Contracting State stays is present 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 fiscal year concerned, he the individual shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his the individual’s activities referred to above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. Income derived by an individual who is a resident of a Contracting Co ntracting State in respect of professional services or other activities of an independent character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, 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 fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

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 he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base. For the purposes of this purposeAgreement, where an individual who is a resident of a Contracting State stays is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month twelve -month period commencing or ending in the fiscal 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 above that are performed in that other State shall be attributable to that fixed base.

INDEPENDENT PERSONAL SERVICES. 1. § 1 Income derived by an individual who is a resident of a Contracting State in respect of professional services or other similar activities of an independent character shall be taxable only in that State unless 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 thepurpose of performing his activities. If he has such a fixed base; in that case, the income may be taxed in the other Contracting State but only so much of it the income as is attributable to that fixed base. For this purpose, where an individual who is a resident of a Contracting State stays base may be taxed in that other 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 any twelve-month period commencing or ending in the fiscal calendar year concerned, he shall be deemed to have a fixed base regularly available to him ; in that other State and case, only so much of the income that as is derived from his activities referred to above that are performed in that other State shall in the year concerned may be attributable to that fixed basetaxed in thatother State.