Article 14 - Independent Personal Services

Independent Personal Services: taxable in resident state unless fixed base or substantial presence permits source-state taxation.

Income of a resident individual from professional or similar independent activities 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 income from activities performed there when the individual's presence in that State aggregates to 90 days in the fiscal year; only income derived from activities performed in that State may then be taxed by that State.