Dependent personal services: employment income taxed in resident state unless exercised abroad; limited presence and nonresident employer exceptions.

Article 15 provides that remuneration from employment is taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exception preserves exclusive residence state taxation where the employee's presence in the other State is of limited duration, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's State.

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