What Are Independent Personal Services?
Independent Personal Service is a tax-treaty income category covering professional or self-employed activity, under which the residence country generally taxes fees unless treaty conditions apply.
Also known as: Article 14 Income, Independent Professional Services.
How Independent Personal Service works
Independent Personal Service income is earned by a self-employed professional, and under Article 14 of the UN Model Convention the residence country taxes the fees unless the professional has a fixed base regularly available in the other country or stays there for 183 days or more in any twelve-month period. When either trigger applies, the host country may tax only the income attributable to the fixed base or to activities performed there. The residence country then generally relieves double taxation by exemption or credit. Treaties following the current OECD Model usually contain no separate article, so such income falls under the business profits article, and wording varies treaty by treaty.
Independent Personal Service vs Dependent Personal Services
Unlike Dependent Personal Services, which cover employment income under the employment article, Independent Personal Service income comes from self-employed professional activity and turns on a fixed base or day-count trigger.
Example
Illustrative example: A consultant resident in Country A works from a rented office in Country B for several months under a treaty containing Article 14. If the office counts as a fixed base, Country B may tax fees attributable to it, while Country A generally grants relief.
Common misconception
Myth: Freelancers are taxable in a host country only after spending 183 days there.
Reality: Independent Personal Service income may become taxable in the host country earlier if a fixed base is regularly available there, and some treaties use different tests.
Frequently asked questions
What is a fixed base?
A fixed base is a place, such as an office or consulting room, regularly available to a self-employed professional in the other treaty country, which allows that country to tax attributable Independent Personal Service income.
Does the 183-day rule apply to freelancers?
Under UN Model Article 14, Independent Personal Service income becomes taxable in the host country after stays of 183 days or more in any twelve-month period, though individual treaties may use different periods or omit the article.
Related terms
- Permanent Establishment (PE) — Business profits concept replacing fixed base in OECD treaties
- Fixed Place of Business — Core test comparable to the fixed base
- United Nations Model Convention — Model treaty retaining Article 14
- Source Taxation — Host country taxing right over attributable fees
- Treaty Resident — Determines which country is the residence State
Related guides
- Tax treaties and international taxation — Treaty allocation of taxing rights
- Georgia freelancer tax guide — Freelancer taxation in a nomad destination
Sources
Last verified: 2026-10-08. This entry is general information, not tax or legal advice; rules vary by country and change over time.
