Independent personal services taxation: residence rule yields to fixed base, substantial presence, or locally paid remuneration allowing limited source taxation. Taxation of independent personal services is allocated to the resident State except where a fixed base exists in the other State, the person's presence in the other State exceeds specified extended periods, or remuneration for activities is paid by a resident or borne by a permanent establishment or fixed base in the other State and exceeds a specified annual threshold; in those cases the other State may tax only the income attributable to that fixed base or to activities performed in that State. 'Professional services' expressly covers independent scientific, literary, artistic, educational or teaching activities and specified professional occupations.
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 taxation: residence rule yields to fixed base, substantial presence, or locally paid remuneration allowing limited source taxation.
Taxation of independent personal services is allocated to the resident State except where a fixed base exists in the other State, the person's presence in the other State exceeds specified extended periods, or remuneration for activities is paid by a resident or borne by a permanent establishment or fixed base in the other State and exceeds a specified annual threshold; in those cases the other State may tax only the income attributable to that fixed base or to activities performed in that State. "Professional services" expressly covers independent scientific, literary, artistic, educational or teaching activities and specified professional occupations.
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