DT7314 - DT: France: double taxation agreement, Article 14 Independent personal services

(1) Income derived by a resident of a Contracting State in respect of independent professional activities 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.

(2) The term `independent professional activities` means all the activities--other than commercial, industrial or agricultural activities--carried on by a person who receives the proceeds or bears the losses arising from those activities.