Dependent personal services taxable in resident state unless employment exercised abroad; exemption requires limited presence and nonresident employer.

Article 15 provides that remuneration for dependent personal services is taxable only in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exemption applies where the individual has only a limited presence in the other State, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base; remuneration from employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.

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