Independent personal services: taxable in resident State unless a fixed base in the other State results in attributable taxable income.

Article 14 provides that income from independent personal services of a resident individual is taxable only in the State of residence unless the individual has a fixed base in the other Contracting State; income attributable to that fixed base may be taxed by the other State. Prolonged aggregate presence in the other State within a relevant twelve month period is treated as creating a deemed fixed base, and income from activities performed there is attributable to that base.

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