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Article 15. INDEPENDENT PERS°'AL SERVICES

U.S. Income Tax Treaty — Technical Explanation - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States

In dealing with the taxation of income from personal services, the Convention distinguishes between "independent" and "dependent" personal services, The Convention also provides special treatment with respect

to individuals who are public entertainers.

Under paragraph (1), income derived by an individual resident of one Contracting State from the performance of personal services in an independent capacity may be taxed only by that Contracting State, How­ ever, under paragraph (2), such income derived from services performed in the other Contracting State may also be taxed in that other Contracting State in certain circumstances. Thus, if the individual has a fixed base regularly available to him in the other Contracting State for the purpose o! performing his activities, r-æ may l:!e taxed by that State, but only on the income that is attributable to that fixed base (the term fixed base is synonymous with the term "permanent establishment" as described in

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▸Contents — U.S. Income Tax Treaty — Technical Explanation - 1976
U.S. Income Tax Treaty — Technical Explanation - 1976

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