Independent personal services: resident state taxation, but a fixed base or prolonged presence allows source state taxation. Income from independent personal services is taxable only in the resident State, except where the individual has a fixed base in the other Contracting State-then only income attributable to that base may be taxed there-or where the individual's presence in the other State meets the prescribed threshold period, in which case only income from activities performed in that other State may be taxed by that State.
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 state taxation, but a fixed base or prolonged presence allows source state taxation.
Income from independent personal services is taxable only in the resident State, except where the individual has a fixed base in the other Contracting State-then only income attributable to that base may be taxed there-or where the individual's presence in the other State meets the prescribed threshold period, in which case only income from activities performed in that other State may be taxed by that State.
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