Taxation of independent personal services: residence-based taxation with exceptions for fixed base presence and extended stay allowing source-country taxation. Income from an individual resident's professional or independent activities is taxable only in the residence territory except where the individual has a fixed base in the other territory-in which case only income attributable to that fixed base may be taxed there-or where the individual's aggregate stay in the other territory reaches an extended threshold within a twelve month period, in which case only income from activities performed in that other territory may be taxed there.
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 with exceptions for fixed base presence and extended stay allowing source-country taxation.
Income from an individual resident's professional or independent activities is taxable only in the residence territory except where the individual has a fixed base in the other territory-in which case only income attributable to that fixed base may be taxed there-or where the individual's aggregate stay in the other territory reaches an extended threshold within a twelve month period, in which case only income from activities performed in that other territory may be taxed there.
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