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ARTICLE 14

U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996 · 2026-10-03 edition · updated 2026-10-04 · United States

Independent Personal Services

  1. Income derived by an individual who is a resident of a Contracting State in respect of the performance of personal services of an independent character shall be taxable only in that State, unless the individual has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income attributable to the fixed base that is derived in respect of services performed in that other State also may be taxed by that other State.

  2. For purposes of paragraph 1, the income that is taxable in the other Contracting State shall be determined under the principles of paragraph 3 of Article 7.

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▸Contents — U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996
U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996

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