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HMRC internal manual

Double Taxation Relief Manual

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

(1) Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar character shall be taxable only in that State unless. for the purpose of performing his activities, he has a fixed base regularly available to him in the other Contracting State or he is present in that other Contracting State for a period or periods exceeding in the aggregate 183 days in the fiscal year concerned. If he has such a fixed base or is so present for such period or periods, the income may be taxed in the other Contracting State but only so much of it as is attributable to that fixed base or to the aforementioned period or periods.

(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.