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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Ivory Coast: double taxation agreement, Article 15: Independent personal services

(1) Subject to the provisions of Article 13, income derived by a resident of aContracting State in respect of professional services or other activities of anindependent character shall be taxable only in that State unless he:

  1. has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; or
  2. carries on such professional services or such other activities of independent character in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any period of 12 months.

In these cases the income shall be taxable in that other State but only so much of itas is attributable to the activities carried on through the fixed base or for the saidperiod or periods.

(2) The term `professional services` includes especially independent scientific,literary, artistic, educational or teaching activities as well as the independentactivities of physicians, lawyers, engineers, architects, dentists and accountants.