Taxation of employment income: source state may tax if employment is exercised there, subject to short term presence and employer residence limits.

Remuneration derived by a resident is 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. An exception confines taxation to the resident State where the presence in the other State is short-term, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for employment on ships or aircraft in international traffic is taxed in the State of the enterprise's place of effective management.

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