Browse 6 Gruv blog articles tagged Fixed Base. Tax filings, invoicing rules, and treaty guidance for cross-border operators.
For U.S.-Mexico cross-border tax decisions, use this order: confirm residency, map income and relief, then test business-presence risk. The common failure is to reverse that order and file credits or treaty forms before your residency facts are coherent.
Start with the default rule. Under **Article 14 (Independent Personal Services)**, your income is generally taxable only in your country of residence. That changes if the services are performed in the other country and a treaty trigger is met.
Start with residency facts you can prove, then choose your filing position, then choose structure. That order helps keep filings consistent and reduces avoidable contradictions.
A permanent establishment, or PE, is a business-presence threshold used in many income tax treaties. It helps decide whether a source country may tax an enterprise’s business profits and which profits are attributable there. Start with the actual taxpayer, its treaty residence, the income and the country of activity—not a travel-day score.
Start with the treaty text before you decide anything. For **us india dtaa independent personal services**, use this order. Open the [U.S.-India Tax Convention PDF](https://www.irs.gov/pub/irs-trty/india.pdf), then the [Technical Explanation](https://www.irs.gov/pub/irs-trty/inditech.pdf). The Technical Explanation states that it is an official guide to the Convention.
An independent personal services article allocates taxing rights for specified self-employed professional income between treaty countries. It can restrict source-country tax when its residence, fixed-base and other conditions are met. The bilateral treaty controls: the article is not always numbered 14, and some treaties treat independent services under business profits instead. For a nonresident alien individual claiming exemption on services performed in the United States, Form 8233 supplies the payment-time claim process.
