Dependent personal services: residence-based taxation subject to limited presence, employer residence, and permanent establishment conditions.

Dependent personal services are taxable in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration remains taxable only in the resident State where the worker's presence in the other State falls below a limited presence threshold, the payor is a non-resident employer, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State; employment aboard internationally operated ships or aircraft is taxable only in the State of the enterprise's place of effective management.

---

---

---