Fixed base rule governs taxation of independent professional services and limits taxing rights to attributable income. Income of a resident individual from independent professional services is taxable only in the resident State unless the individual has a fixed base in the other State; if such a fixed base exists, the other State may tax only the income attributable to that base, and an aggregate stay beyond a specified twelve month threshold in the other State is deemed to create such a fixed base, making income from activities performed there attributable to it.
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.
Fixed base rule governs taxation of independent professional services and limits taxing rights to attributable income.
Income of a resident individual from independent professional services is taxable only in the resident State unless the individual has a fixed base in the other State; if such a fixed base exists, the other State may tax only the income attributable to that base, and an aggregate stay beyond a specified twelve month threshold in the other State is deemed to create such a fixed base, making income from activities performed there attributable to it.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
