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.

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