Independent personal services: source-state taxation possible when fixed base or prolonged presence permits attribution of income. Article 14 provides that a resident's income from professional or similar independent activities is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there, and may tax income from activities performed in that State where the individual's aggregate stay in that State in the fiscal year meets the specified threshold for presence. 'Professional services' includes independent scientific, literary, artistic, educational activities and listed professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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Provisions expressly mentioned in the judgment/order text.
Independent personal services: source-state taxation possible when fixed base or prolonged presence permits attribution of income.
Article 14 provides that a resident's income from professional or similar independent activities is taxable only in the State of residence, except that the other Contracting State may tax income attributable to a fixed base regularly available there, and may tax income from activities performed in that State where the individual's aggregate stay in that State in the fiscal year meets the specified threshold for presence. "Professional services" includes independent scientific, literary, artistic, educational activities and listed professions such as physicians, lawyers, engineers, architects, dentists and accountants.
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