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 ... Summary
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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.