Taxation of independent personal services: source state may tax only income tied to a fixed base or extended presence.

Income from independent personal services is taxable only in the taxpayer's state of residence unless the taxpayer has a fixed base regularly available in the other Contracting State or is present in that other State beyond the treaty's presence threshold; if either condition is met, the other State may tax only the income attributable to that fixed base or derived during the period of presence. Professional services include independent scientific, literary, artistic, educational or teaching activities and independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.

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