Independent personal services may be taxed in another state if a fixed base exists or presence exceeds the threshold.

Income from independent professional services of a resident is taxable only in the resident State unless the resident has a fixed base in the other State, in which case income attributable to that fixed base may be taxed there, or unless the resident's presence in the other State for performing the activities exceeds the treaty's duration threshold, in which case income attributable to activities performed there may be taxed by that other State.

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