Taxation of independent personal services: presence or fixed base may permit source-state taxation of related income.

Income from independent personal services of a resident is taxable only in the resident State, except where the individual has a fixed base in the other Contracting State-allowing taxation only of income attributable to that fixed base-or where the individual's aggregated presence in the other State meets the duration threshold, permitting taxation only of income from activities performed there.

---

---

---