Taxation of independent personal services: presence beyond the statutory threshold permits source-state taxation if income is attributable. Taxation of income from independent personal services under the DTAA is limited to cases where the service-provider is present in the source State beyond the prescribed threshold in the relevant tax year, and then only to the extent that income is attributable to services performed in that State; professional services include independent scientific, literary, artistic, educational or teaching activities and certain professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services: presence beyond the statutory threshold permits source-state taxation if income is attributable.
Taxation of income from independent personal services under the DTAA is limited to cases where the service-provider is present in the source State beyond the prescribed threshold in the relevant tax year, and then only to the extent that income is attributable to services performed in that State; professional services include independent scientific, literary, artistic, educational or teaching activities and certain professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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