Independent personal services taxable in resident state unless fixed base or extended stay triggers other-state taxation. Income from independent professional services is taxable only in the taxpayer's residence State except where the individual has a fixed base regularly available in the other Contracting State, in which case only income attributable to that fixed base may be taxed there, or where the individual's stay in the other State meets an extended stay threshold, in which case only income derived from activities performed in that State may be taxed there. 'Professional services' expressly includes independent scientific, literary, artistic, educational or teaching activities and listed professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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 extended stay triggers other-state taxation.
Income from independent professional services is taxable only in the taxpayer's residence State except where the individual has a fixed base regularly available in the other Contracting State, in which case only income attributable to that fixed base may be taxed there, or where the individual's stay in the other State meets an extended stay threshold, in which case only income derived from activities performed in that State may be taxed there. "Professional services" expressly includes independent scientific, literary, artistic, educational or teaching activities and listed professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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