Under domestic law, income tax is charged on the profits of any profession or vocation under ITTOIA 2005, s. 5. This is distinguished in certain respects from the income of a trade, but the territorial scope of the charge is identical.95 For many years, UK treaties, particularly those patterned on the OECD 1963 draft and 1977 model, have distinguished between business profits in art. 7 and ‘professional services and other activities of an independent character’ referred to in art. 14.

One such treaty is the UK-Belgium Treaty, which provides that:

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