Taxation of independent personal services: resident state has exclusive right, subject to fixed-base or presence threshold exceptions. Income from independent personal services of a resident is taxable only in the resident State, except that the other Contracting State may tax income attributable to a fixed base regularly available there, or may tax income from activities performed there if the individual's presence meets an aggregate presence threshold within the relevant twelve month period. Professional services are defined to include independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, surgeons, dentists 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: resident state has exclusive right, subject to fixed-base or presence threshold exceptions.
Income from independent personal services of a resident is taxable only in the resident State, except that the other Contracting State may tax income attributable to a fixed base regularly available there, or may tax income from activities performed there if the individual's presence meets an aggregate presence threshold within the relevant twelve month period. Professional services are defined to include independent scientific, literary, artistic, educational or teaching activities and specified professions such as physicians, lawyers, engineers, architects, surgeons, dentists and accountants.
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