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.

---

---

---