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of <h1>Income from Professional Services Taxable in Both States if Fixed Base Exists or Stay Exceeds 183 Days</h1> Income from professional services or independent activities by a resident of one Contracting State is generally taxable only in that State. However, it may also be taxed in the other Contracting State if the individual has a fixed base there for performing activities or stays there for 183 days or more within a 12-month period. In such cases, only income attributable to the fixed base or activities performed during the stay is taxable in the other State. 'Professional services' include independent activities in fields like science, literature, art, education, and professions such as medicine, law, engineering, and accounting.
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