Taxation of independent services: resident's income taxed in residence, except where fixed base or prolonged stay creates source tax. Income of a resident from independent personal services is taxable only in the residence State except where (a) a fixed base in the other State exists, permitting taxation of income attributable to that base, or (b) the individual's presence in the other State meets the treaty's duration threshold, permitting taxation of 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 services: resident's income taxed in residence, except where fixed base or prolonged stay creates source tax.
Income of a resident from independent personal services is taxable only in the residence State except where (a) a fixed base in the other State exists, permitting taxation of income attributable to that base, or (b) the individual's presence in the other State meets the treaty's duration threshold, permitting taxation of income derived from activities performed there.
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 
