Dependent personal services: residency-based taxation limited by short-term presence and employer/PE conditions determining taxing rights.

Salaries, wages and similar remuneration paid to a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. Remuneration exercised in the other State is taxable only in the resident State if the worker's presence is within the treaty's short-term presence rule, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there; special taxation applies for employment aboard ships or aircraft in international traffic.

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