Taxation of independent personal services: residence-state primary rule, source taxation possible for fixed base or excessive presence. Income of a resident individual from independent professional services performed in the other Contracting State is taxable only in the State of residence, except where the income is attributable to a fixed base regularly available in the other State or where the recipient's presence in the other State exceeds the treaty's specified presence threshold; professional services expressly include independent scientific, literary, artistic, educational activities and specified professions.
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Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services: residence-state primary rule, source taxation possible for fixed base or excessive presence.
Income of a resident individual from independent professional services performed in the other Contracting State is taxable only in the State of residence, except where the income is attributable to a fixed base regularly available in the other State or where the recipient's presence in the other State exceeds the treaty's specified presence threshold; professional services expressly include independent scientific, literary, artistic, educational activities and specified professions.
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