Taxation of independent personal services: residence taxation with source taxation where a fixed base or extended stay exists.

Income of a resident from independent professional services is taxable only in the State of residence except where the resident has a fixed base in the other Contracting State-then income attributable to that fixed base may be taxed there-or where the resident's stay in the other State aggregates the treaty threshold in a twelve month period, in which case income from activities performed in that State may be taxed there. "Professional services" is defined to include specified independent occupations and activities.

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