Taxation of independent personal services: resident state taxation unless fixed base, prolonged presence, or locally borne remuneration.

Income from independent personal services of a resident is taxable only in that resident State, except where the individual has a fixed base in the other State - in which case income attributable to that fixed base may be taxed there - or where sustained presence in the other State or remuneration paid by residents or borne by a non-resident's permanent establishment triggers taxation subject to a specified threshold.

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