Dependent personal services taxation: remuneration taxed in resident state unless employment is exercised abroad, subject to presence and employer conditions.

Remuneration of a resident is taxable only in the State of residence unless employment is exercised in the other Contracting State, where such remuneration may be taxed; however, remuneration remains taxable only in the State of residence if the employee's presence in the other State is limited, the employer is not resident in that other State, and the pay is not borne by a permanent establishment or fixed base there. Remuneration from employment aboard ships or aircraft in international traffic may be taxed in the State of operation.

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