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HMRC internal manual

Double Taxation Relief Manual

DT: Philippines: double taxation agreement, Article 13 Independent personal services

(1) Income derived by a resident of a Contracting State in respect of professionalservices or other independent activities of a similar character shall be taxable only inthat State, unless:

  1. he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State; or

  2. his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 120 days in the calendar year.

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