Independent personal services: taxable in residence unless income is attributable to a fixed base or presence over the threshold. Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where such services are ... Summary
Independent personal services: taxable in residence unless income is attributable to a fixed base or presence over the threshold.
Income from independent personal services earned by a resident is generally taxable only in the State of residence, except where such services are performed in the other State and the income is attributable to a fixed base regularly available there, or where the recipient's presence in that other State exceeds the treaty's temporal threshold permitting source-state taxation.
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