Independent Personal Services: income taxable in resident state unless a fixed base abroad allows taxation of attributable income. Income from Independent Personal Services by a resident is taxable only in the resident State unless the resident has a fixed base in the other Contracting State; if a fixed base exists, the other State may tax only the income attributable to that fixed base, with 'professional services' defined by each Contracting State's laws and regulations.
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: income taxable in resident state unless a fixed base abroad allows taxation of attributable income.
Income from Independent Personal Services by a resident is taxable only in the resident State unless the resident has a fixed base in the other Contracting State; if a fixed base exists, the other State may tax only the income attributable to that fixed base, with "professional services" defined by each Contracting State's laws and regulations.
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