Taxation of Independent Personal Services limited to resident state unless fixed base, prolonged presence, or local remuneration.

Income from independent personal services of a resident individual or firm of individuals is taxable only in the resident Contracting State, except where the individual has a fixed base in the other Contracting State-then only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets the presence threshold, or where remuneration is derived from residents of the other State or borne by a permanent establishment of a non resident in that State and exceeds the treaty threshold for the fiscal year.

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