Taxation of independent personal services: residence-based rule with fixed base or prolonged presence exceptions allowing source-state taxation. Income from independent professional activities is taxable only in the resident State except where the individual has a fixed base in the other Contracting State-then only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets a duration threshold, in which case only income from activities performed in that State may be taxed by that State.
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.
Taxation of independent personal services: residence-based rule with fixed base or prolonged presence exceptions allowing source-state taxation.
Income from independent professional activities is taxable only in the resident State except where the individual has a fixed base in the other Contracting State-then only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State meets a duration threshold, in which case only income from activities performed in that State may be taxed by that State.
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