Taxation of Independent Personal Services may be taxed in another state if a fixed base exists or prolonged presence occurs. Income of a resident individual from independent professional services is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there or income earned during a qualifying period of presence in that other State; in both cases taxation by the other State is limited to the income attributable to the fixed base or to the activities performed in that State. 'Professional services' includes independent scientific, literary, artistic, educational or teaching activities and listed professions such as physicians, lawyers 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 Personal Services may be taxed in another state if a fixed base exists or prolonged presence occurs.
Income of a resident individual from independent professional services is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there or income earned during a qualifying period of presence in that other State; in both cases taxation by the other State is limited to the income attributable to the fixed base or to the activities performed in that State. "Professional services" includes independent scientific, literary, artistic, educational or teaching activities and listed professions such as physicians, lawyers and accountants.
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