Taxation of independent personal services: residence-state taxation, but other state may tax income tied to fixed base or prolonged presence.

Income of a resident individual from professional or similar independent activities is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base there or income from activities performed there if the individual's stay in that State meets the treaty's prolonged-presence threshold. "Professional services" is defined to include independent scientific, literary, artistic, educational or teaching activities and specifically names physicians, lawyers, engineers, architects, surgeons, dentists and accountants.

---

---

---