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HMRC internal manual

Double Taxation Relief Manual

DT: Kazahkstan: double taxation agreement, Article 14: Independent personal services

  1. Income derived by 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 unless such services are performed or were performed in the other Contracting State; and
(a) the income is attributable to a fixed base which the individual has or had regularly available to him in that other State; or  
(b) such individual is present or was present in that other State for a period or periods exceeding 183 days in any consecutive twelve-month period.

If he has or had such a fixed base or is or was so present, the income may be taxed in the other State but only so much of it as is attributable to that fixed base or to professional services performed in that Contracting State in that twelve-month period.

  1. 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.