Independent personal services: income taxed in resident State unless a fixed base abroad makes attributable income taxable there.

Income from independent personal services of a resident is taxable only in the resident State unless the individual has a fixed base in the other State; if a fixed base exists the other State may tax only income attributable to that fixed base. A presumption of a fixed base arises from exceeding a specified presence threshold in a twelve month period, and income from activities performed in that other State is attributable to the fixed base.

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