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of <h1>Income from professional activities is taxable only in the resident state unless a fixed base or 183-day presence exists.</h1> Income earned by an individual resident in one Contracting State from professional or similar independent activities is generally taxable only in that State. However, it may also be taxed in the other Contracting State if the individual has a fixed base there for performing activities, or if the individual stays in the other State for 183 days or more in a taxable period. In such cases, only the income attributable to the fixed base or activities performed in the other State is taxable there. 'Professional services' include independent scientific, literary, artistic, educational, and various professional activities.
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