МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 14
                    Independent personal services

     1.  Income  derived  by  an  individual  who  is  a resident of a
Contracting  State  in  respect  of  professional  services  or  other
activities  of  an independent character shall be taxable only in that
State. However, such income may also be taxed in the other Contracting
State if:
     a)  the individual has a fixed base regularly available to him in
that  other  State  for  the purpose of performing his activities, but
only so much thereof as is attributable to that fixed base; or
     b)  the individual is present in that other State for a period or
periods  exceeding  in  the  aggregate  183  days  within any 12-month
period,  but  only  so much thereof as is attributable to the services
performed in that State; or
     c)  the  remuneration for his activities in the other Contracting
State  is  paid by or on behalf of a resident of the other Contracting
State  or  is  borne  by  a  permanent  establishment  or a fixed base
situated  in  that  Contracting State and exceeds in the fiscal year a
gross amount equivalent to 20,000 US dollars.
     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.