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.
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: 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.
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