Taxation of independent personal services: presence or fixed base may permit source-state taxation of related income. Income from independent personal services of a resident is taxable only in the resident State, except where the individual has a fixed base in the other Contracting State-allowing taxation only of income attributable to that fixed base-or where the individual's aggregated presence in the other State meets the duration threshold, permitting taxation only of income from activities performed there.
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Taxation of independent personal services: presence or fixed base may permit source-state taxation of related income.
Income from independent personal services of a resident is taxable only in the resident State, except where the individual has a fixed base in the other Contracting State-allowing taxation only of income attributable to that fixed base-or where the individual's aggregated presence in the other State meets the duration threshold, permitting taxation only of income from activities performed there.
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