Independent personal services: resident state taxation, but source state may tax income from a fixed base or prolonged presence. Income from independent personal services of a resident individual is taxable only in the State of residence, except where the individual has a fixed base regularly available in the other Contracting State-allowing taxation only on income attributable to that fixed base-or where the individual's extended presence in the other State permits taxation only on income derived from activities performed 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.
Independent personal services: resident state taxation, but source state may tax income from a fixed base or prolonged presence.
Income from independent personal services of a resident individual is taxable only in the State of residence, except where the individual has a fixed base regularly available in the other Contracting State-allowing taxation only on income attributable to that fixed base-or where the individual's extended presence in the other State permits taxation only on income derived from activities performed there.
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