Taxation of independent personal services: resident state has primary taxing right, except for fixed base or extended-stay exceptions. 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, in which case income attributable to that fixed base may be taxed there, or where the individual's presence in the other State meets an extended-stay threshold within a 12 month period, in which case only income from activities performed there may be taxed.
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 has primary taxing right, except for fixed base or extended-stay exceptions.
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, in which case income attributable to that fixed base may be taxed there, or where the individual's presence in the other State meets an extended-stay threshold within a 12 month period, in which case only income from activities performed there may be taxed.
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