Independent services taxation: home state primarily taxed; source state may tax income tied to local fixed base or extended presence. Income of a resident from independent personal services 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 from activities performed in that State when the individual's presence meets the treaty's extended presence threshold; only the income attributable to the fixed base or to activities performed in that State may be taxed by the other State.
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 services taxation: home state primarily taxed; source state may tax income tied to local fixed base or extended presence.
Income of a resident from independent personal services 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 from activities performed in that State when the individual's presence meets the treaty's extended presence threshold; only the income attributable to the fixed base or to activities performed in that State may be taxed by the other State.
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