Independent personal services: taxable in resident state except where a fixed base or extended presence permits source-state taxation.

Independent personal services income of a resident is taxable only in the State of residence 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 treaty's presence rule-then only income from activities performed in that State may be taxed there. "Professional services" includes independent scientific, literary, artistic, educational or teaching activities and specified professions.

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