DT3877 - Botswana: double taxation agreement, Article 13 Independent personal services

  1. Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar character shall not be taxable in the other Contracting State if he is subject to tax in respect thereof in the Contracting State of which he is a resident 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.

  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