AUSTRALIAN TAX TREATIES
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 but such income may also be taxed in the other Contracting State if the individual:
(a) has a fixed base regularly available in the other Contracting State for the purpose of performing the individual ' s activities. If such a fixed base is available to the individual, the income may be taxed in the other State but only so much of the income as is attributable to that fixed base; or
(b) is present in the other State for a period or periods exceeding in the aggregate 183 days in any 12 month period commencing or ending in the fiscal period or year of income concerned. If the individual is so present only so much of the income as is attributable to the activities performed in the other State may be taxed in that State. 2
The term " professional services " includes services performed in the exercise of independent scientific, literary, artistic, educational or teaching activities as well as in the exercise of the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
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