Independent personal services: taxable in resident State unless fixed base or substantial presence allows taxation elsewhere. Income from independent personal services of a resident is taxable only in the State of residence, except where the person has a fixed base regularly available in the other Contracting State-then only the income attributable to that fixed base may be taxed there-or where the person is present in the other State for periods aggregating more than 120 days, in which case that State may tax the income.
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 allows taxation elsewhere.
Income from independent personal services of a resident is taxable only in the State of residence, except where the person has a fixed base regularly available in the other Contracting State-then only the income attributable to that fixed base may be taxed there-or where the person is present in the other State for periods aggregating more than 120 days, in which case that State may tax the income.
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