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ARTICLE 14

U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Independent Personal Services

This Article concerns the taxation of income derived by a resident of one of the Contracting States from independent personal services.

The rule established in this Article is that, if an individual who is a resident of one Contracting State performs independent personal services in the other Contracting State, the income from those services may be taxed by that other State if the individual either is present in that other State for an aggregate of more than 183 days in the taxable year (or income year) or has a fixed base regularly available to him in that other State for the purpose of performing his activities. In the latter case, the other State may tax the income for services performed in that other State which is attributable to that fixed base.

It is understood that the term "fixed base" is analogous to the term "permanent establishment." Independent personal services include all personal services performed by an individual for his own account, including services performed as a partner in a partnership, where he receives the income and bears the losses arising from such services, except that services performed as a director of a company are covered by Article 15 (Dependent Personal Services).

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▸Contents — U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf
U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf

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