Independent personal services: taxing rights apply where a fixed base exists or prolonged presence triggers source-state taxation. Income from independent personal services by a resident is taxable only in the resident State, except that if the individual has a fixed base in the other Contracting State, income attributable to that base may be taxed there, and if the individual's stay in the other State aggregates to 183 days or more, income from activities performed there may be taxed by that State. 'Professional services' is defined to include specified independent professional and artistic occupations.
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: taxing rights apply where a fixed base exists or prolonged presence triggers source-state taxation.
Income from independent personal services by a resident is taxable only in the resident State, except that if the individual has a fixed base in the other Contracting State, income attributable to that base may be taxed there, and if the individual's stay in the other State aggregates to 183 days or more, income from activities performed there may be taxed by that State. "Professional services" is defined to include specified independent professional and artistic occupations.
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