Independent personal services: taxable in resident state unless a fixed base or extended presence allows taxation by the other state. Income from independent personal services by a resident of one Contracting State is taxable only in that State, except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State reaches the duration threshold within a 12 month period, in which case only income from activities performed in that other State may be taxed there.
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 a fixed base or extended presence allows taxation by the other state.
Income from independent personal services by a resident of one Contracting State is taxable only in that State, except where the individual has a fixed base in the other State-then only income attributable to that fixed base may be taxed there-or where the individual's presence in the other State reaches the duration threshold within a 12 month period, in which case only income from activities performed in that other State may be taxed there.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
