If this is the case one asks why there are exceptions for Article. 8 (Shipping, etc. and Air Transport) and 17 (Artistes and Sportspersons)? There seems, in fact, to be a particular analogy between often very highly paid entertainers who can perform a full economic cycle of activity within a country or city with only limited and often very internally mobile presence on the one hand, and other service providers on the other. Analogous treatment may be especially apt to often very highly paid service providers of other types.
The UN Model Convention perspective is that provision of services, as with Article. 17 situations, has relevantly special characteristics, and fairness (inter-nation equity) to source countries dictates that the normal “bricks and mortar” presence is not the right minimum economic footprint for taxation of services by the host country. Several OECD Member countries obviously follow this general approach, as noted below.