Taxation of independent personal services: source state may tax income attributable to services performed there when presence or fixed base conditions apply. The DTAA permits the resident State to tax income from professional or similar independent activities but allows the other Contracting State to tax income attributable to services performed there where the service provider meets specified presence conditions or has a fixed base regularly available for performing the activities; 'professional services' includes specified independent occupations such as scientific, literary, artistic, educational activities and listed professions.
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.
Taxation of independent personal services: source state may tax income attributable to services performed there when presence or fixed base conditions apply.
The DTAA permits the resident State to tax income from professional or similar independent activities but allows the other Contracting State to tax income attributable to services performed there where the service provider meets specified presence conditions or has a fixed base regularly available for performing the activities; "professional services" includes specified independent occupations such as scientific, literary, artistic, educational activities and listed professions.
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