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Taxation of independent personal services: resident-state taxation unless fixed base allows source-state taxation of attributable income. Income derived by a resident in respect of professional services or other independent activities shall be taxable only in the resident State unless the resident has a fixed base regularly available in the other Contracting State for performing his activities; if such a fixed base exists, the other State may tax only the income attributable to that fixed base.
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.
Taxation of independent personal services: resident-state taxation unless fixed base allows source-state taxation of attributable income.
Income derived by a resident in respect of professional services or other independent activities shall be taxable only in the resident State unless the resident has a fixed base regularly available in the other Contracting State for performing his activities; if such a fixed base exists, the other State may tax only the income attributable to that fixed base.
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