Independent Personal Services: taxable in resident state; source state may tax income tied to a fixed base or substantial presence. Income from independent personal services is taxable only in the resident Contracting State except where a fixed base in the other State exists-allowing taxation only of income attributable to that fixed base-or where the resident's sustained presence in the other State meets the applicable threshold, permitting taxation only of income derived from activities performed there. 'Professional services' includes independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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: taxable in resident state; source state may tax income tied to a fixed base or substantial presence.
Income from independent personal services is taxable only in the resident Contracting State except where a fixed base in the other State exists-allowing taxation only of income attributable to that fixed base-or where the resident's sustained presence in the other State meets the applicable threshold, permitting taxation only of income derived from activities performed there. "Professional services" includes independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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