Independent personal services: resident taxed in home state unless fixed base in source state permits taxation of attributable income. Income from independent personal or professional services earned by a resident is taxable only in the resident state unless the individual has a fixed base regularly available in the other Contracting State; if a fixed base exists, the other state may tax only the income attributable to that fixed base. The term professional services includes independent scientific, literary, artistic, educational and teaching activities and independent practitioners such as physicians, lawyers, engineers, architects, dentists and accountants.
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: resident taxed in home state unless fixed base in source state permits taxation of attributable income.
Income from independent personal or professional services earned by a resident is taxable only in the resident state unless the individual has a fixed base regularly available in the other Contracting State; if a fixed base exists, the other state may tax only the income attributable to that fixed base. The term professional services includes independent scientific, literary, artistic, educational and teaching activities and independent practitioners such as physicians, lawyers, engineers, architects, dentists and accountants.
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