Independent Personal Services: OECD treats them as Business Profit while UN model allows taxation via fixed base or substantial presence.

Article 14 has been removed from the OECD Model so income from professional services is now treated as Business Profit. Under the UN Model, income from professional or other independent activities is taxable only in the resident State except where the taxpayer has a fixed base in the other State or the taxpayer's presence there meets the threshold for taxation; in those cases only income attributable to the fixed base or derived from activities performed in the other State may be taxed there.

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