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.
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: 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.
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