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. However, such income may also be taxed in the other Contracting State if such services or activities are performed in that other State and:
(a) the individual has a fixed base regularly available in that other State for the purposes of performing those services or activities; or
(b) the individual is present in that other State for the purpose of performing those services or activities for a period or periods exceed in the aggregate 183 days in any 12 month period commencing or ending in the year of income of that other State.
In such circumstances, only so much of the income as is attributable to that fixed base or is derived from the services or activities performed in that other State, as the case may be, may be taxed in that other State.
2.
The term " professional services " includes independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
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