Taxation of independent personal services: income taxed in resident State unless substantial physical presence permits source State taxation. Income of a resident from independent professional or similar activities is taxable only in the State of residence, except that prolonged presence in the other Contracting State permits that State also to tax such income; professional services include independent scientific, literary, artistic, educational or teaching activities and the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
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: income taxed in resident State unless substantial physical presence permits source State taxation.
Income of a resident from independent professional or similar activities is taxable only in the State of residence, except that prolonged presence in the other Contracting State permits that State also to tax such income; professional services include independent scientific, literary, artistic, educational or teaching activities and the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
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