Dependent personal services taxation: income taxed in residence State unless employment is exercised abroad, subject to limited presence exception.

Salaries and similar remuneration paid to a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the pay. However, if the employee's presence in the other State is limited, the employer is not resident there, and the pay is not borne by a permanent establishment or fixed base in that State, taxation remains with the resident State. Remuneration from employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.

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