Independent personal services: residence-state taxation generally, but other-state taxation where fixed base or extended stay triggers source-based tax. Income from independent personal services is taxable only in the resident Contracting State except where the taxpayer has a fixed base in the other State-in which case only income attributable to that fixed base may be taxed there-or where the taxpayer's stay in the other State aggregates 183 days or more in any 12 month period commencing or ending in the fiscal year concerned, in which case only income from activities performed in that other State may be taxed there.
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: residence-state taxation generally, but other-state taxation where fixed base or extended stay triggers source-based tax.
Income from independent personal services is taxable only in the resident Contracting State except where the taxpayer has a fixed base in the other State-in which case only income attributable to that fixed base may be taxed there-or where the taxpayer's stay in the other State aggregates 183 days or more in any 12 month period commencing or ending in the fiscal year concerned, in which case only income from activities performed in that other State may be taxed there.
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