Independent personal services: residence-based taxation, except for income linked to a fixed base or prolonged presence enabling source taxation. Income from an individual's independent professional services is taxable only in the State of residence except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's aggregate presence in the other State exceeds a limited threshold within a twelve month period, in which case only income derived from activities performed there may be taxed by that other State.
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.
Independent personal services: residence-based taxation, except for income linked to a fixed base or prolonged presence enabling source taxation.
Income from an individual's independent professional services is taxable only in the State of residence except where the individual has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the individual's aggregate presence in the other State exceeds a limited threshold within a twelve month period, in which case only income derived from activities performed there may be taxed by that other State.
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