Independent personal services: resident's professional income taxable in residence unless fixed base or prolonged presence permits source state taxation.

Income of a resident individual from independent personal services is taxable only in the State of residence except when the individual has a fixed base in the other Contracting State-in which case only income attributable to that fixed base may be taxed there-or when the individual's aggregate presence in the other State meets the prescribed duration threshold, in which case only income derived from activities performed in that State may be taxed there.

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