Independent personal services may be taxed in the other state if a fixed base exists or stay exceeds treaty threshold. Income from independent personal services is taxable only in the resident State except where the provider has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the provider's presence in the other State meets a treaty-specified stay threshold, in which case only income from activities performed in that 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 may be taxed in the other state if a fixed base exists or stay exceeds treaty threshold.
Income from independent personal services is taxable only in the resident State except where the provider has a fixed base in the other State, in which case only income attributable to that fixed base may be taxed there, or where the provider's presence in the other State meets a treaty-specified stay threshold, in which case only income from activities performed in that State may be taxed there.
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