Independent personal services taxable in resident state unless fixed base or prolonged presence permits source state taxation.

Income from independent personal services of a resident is generally 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 base-or where the individual's presence in the other State meets the treaty's stay threshold, permitting taxation only of income from activities performed there. The term professional services expressly includes independent scientific, literary, artistic, educational or teaching activities and specifies certain professions such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.

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