Independent personal services: residence-state taxation generally exclusive, but other state may tax with fixed base or prolonged presence. Income of a resident individual from professional or similar independent activities is taxable only in the State of residence, 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 stay in the other State aggregates to or exceeds 183 days in a twelve month period - in which case only income from activities performed in that other State may be taxed 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.
Independent personal services: residence-state taxation generally exclusive, but other state may tax with fixed base or prolonged presence.
Income of a resident individual from professional or similar independent activities is taxable only in the State of residence, 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 stay in the other State aggregates to or exceeds 183 days in a twelve month period - in which case only income from activities performed in that other State may be taxed there.
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