Taxation of independent services: resident State primary; source State may tax income from a fixed base or extended stay. Resident taxation of income from independent professional services is primary, but the other Contracting State may tax income attributable to a fixed base regularly available there or income derived from activities performed during an extended stay. 'Professional services' expressly includes independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, 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.
Taxation of independent services: resident State primary; source State may tax income from a fixed base or extended stay.
Resident taxation of income from independent professional services is primary, but the other Contracting State may tax income attributable to a fixed base regularly available there or income derived from activities performed during an extended stay. "Professional services" expressly includes independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, dentists and accountants.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
