Taxation of independent personal services: resident state primarily taxed unless fixed base or prolonged presence in other state. Income from independent personal services is taxable only in the individual's State of residence except where the individual has a fixed base in the other Contracting State-then only income attributable to that base may be taxed there-or where the individual's presence in the other State meets a substantial duration threshold within a twelve month period-then only income from activities performed in that State may be taxed there. 'Professional services' expressly covers specified independent professional and creative occupations.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services: resident state primarily taxed unless fixed base or prolonged presence in other state.
Income from independent personal services is taxable only in the individual's State of residence except where the individual has a fixed base in the other Contracting State-then only income attributable to that base may be taxed there-or where the individual's presence in the other State meets a substantial duration threshold within a twelve month period-then only income from activities performed in that State may be taxed there. "Professional services" expressly covers specified independent professional and creative occupations.
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