Independent personal services taxation: residence-based rule with exceptions for fixed base and qualifying presence allowing source taxation. Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other Contracting State-in which case only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets the treaty period threshold, in which case only income from activities performed in that State may be taxed. 'Professional services' includes independent scientific, literary, artistic, educational and specified professional occupations.
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Provisions expressly mentioned in the judgment/order text.
Independent personal services taxation: residence-based rule with exceptions for fixed base and qualifying presence allowing source taxation.
Income from independent personal services is taxable only in the resident State except where the individual has a fixed base in the other Contracting State-in which case only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets the treaty period threshold, in which case only income from activities performed in that State may be taxed. "Professional services" includes independent scientific, literary, artistic, educational and specified professional occupations.
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