Independent personal services: taxable in resident state, except fixed base or prolonged presence permits source taxation. Income from independent personal services by a resident is taxable only in that State, except where the person has a fixed base in the other State-then ... Summary
Independent personal services: taxable in resident state, except fixed base or prolonged presence permits source taxation.
Income from independent personal services by a resident is taxable only in that State, except where the person has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the person's stay in the other State meets the Convention's prolonged presence threshold, in which case only income from activities performed in that State may be taxed there.
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