Dependent personal services: resident-state taxation applies unless work abroad triggers source-state taxation; exceptions based on presence, employer residence, and PE.

Remuneration for employment by a resident is taxable only in the resident State unless the employment is exercised in the other State, in which case the other State may tax it. Remuneration exercised abroad remains taxable only in the resident State if presence in the other State is limited to a short aggregate period, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Members of the regular complement of ships or aircraft in international traffic are taxable only in the resident State.

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