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HMRC internal manual

Double Taxation Relief Manual

DT: New Zealand: double taxation agreement, Article 15: Independent personal services


(1) 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:


  1. the individual is present in the other State for a period or periods exceeding in the aggregate 183 days in any consecutive period of 12 months; or
  2. the individual has a fixed base regularly available to him in the other State for the purpose of performing his activities;

but only so much thereof as is attributable to services performed in that State.

(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.