Taxation of independent personal services: residence-based taxation subject to fixed base and extended presence exceptions. Income from independent personal services is taxable only in the individual's State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there or income derived from activities performed in that other State where the individual's presence meets an extended physical-presence threshold within a twelve-month period.
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: residence-based taxation subject to fixed base and extended presence exceptions.
Income from independent personal services is taxable only in the individual's State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there or income derived from activities performed in that other State where the individual's presence meets an extended physical-presence threshold within a twelve-month period.
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