Independent personal services: taxable in resident state unless fixed base, substantial presence, or remuneration threshold triggers taxation abroad. Income from independent professional services is taxable only in the resident State unless the individual has a fixed base regularly available in the other State, or is present in the other State beyond the applicable duration threshold, in which cases income attributable to the fixed base or to activities performed there may be taxed by that other State; additionally, remuneration from residents of the other State exceeding an applicable remuneration threshold (excluding travel expenses) permits taxation there. 'Professional services' include independent scientific, literary, artistic, educational or teaching activities and specified independent professions.
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.
Independent personal services: taxable in resident state unless fixed base, substantial presence, or remuneration threshold triggers taxation abroad.
Income from independent professional services is taxable only in the resident State unless the individual has a fixed base regularly available in the other State, or is present in the other State beyond the applicable duration threshold, in which cases income attributable to the fixed base or to activities performed there may be taxed by that other State; additionally, remuneration from residents of the other State exceeding an applicable remuneration threshold (excluding travel expenses) permits taxation there. "Professional services" include independent scientific, literary, artistic, educational or teaching activities and specified independent professions.
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