Australian Tax Treaties
As amended by the United States Protocol (No 1)
Income derived by an individual who is a resident of one of the Contracting States from the performance of personal services in an independent capacity shall be taxable only in that State unless such services are performed in the other Contracting State and:
(a) the individual is present in that other State for a period or periods aggregating more than 183 days in the taxable year or year of income of that other State; or
(b) the individual has a fixed base regularly available to him in that other State for the purpose of performing his activities, in which case so much of the income as is attributable to that fixed base may be taxed in such other State.
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