Article 15 - Independent personal services - Montenegro

ARTICLE 15 INDEPENDENT PERSONAL SERVICES 1. Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other independent activities of an similar character shall be taxable only in the State, except in the following circumstances, when such income may also be taxed in the other Contracting State: 1) if 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) if his in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; in the case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other 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, surgeons, dentists and accountants.