Independent personal services: residency-based taxation generally, but fixed base or substantial presence permits other-state taxation. Income from independent personal services of a resident is taxable only in the State of residence, except that the other Contracting State may tax income ... Summary
Independent personal services: residency-based taxation generally, but fixed base or substantial presence permits other-state taxation.
Income from independent personal services of a resident is taxable only in the 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 there when the individual's presence meets the Treaty's substantial-presence threshold.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.