- 1
- Income derived by a resident of one of the States in respect of professional services or other independent activities of a similar character shall be taxable only in that State. However, in the following circumstances such income may be taxed in the other State:
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- a)if he has a fixed base regularly available to him in the other te for the purpose of performing his activities;
- b)if his stay in the other State is for a period or periods amounting to or exceeding in the aggregate 183 days in the taxable year.
- 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.