Taxation of independent personal services: source taxation allowed where fixed base or prolonged presence permits allocation of tax rights. Income from Independent Personal Services is taxable only in the individual's State of residence 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 stays in the other State meet the specified aggregated-duration threshold within a twelve-month period, permitting taxation by that State solely on income derived from activities performed there.
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 taxation allowed where fixed base or prolonged presence permits allocation of tax rights.
Income from Independent Personal Services is taxable only in the individual's State of residence 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 stays in the other State meet the specified aggregated-duration threshold within a twelve-month period, permitting taxation by that State solely on income derived from activities performed there.
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