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

Dependent personal services are taxable in the resident State unless the employment is exercised in the other State, in which case that State may tax the remuneration. However, source-state taxation is excluded where the employee's presence in the other State remains below a specified presence threshold, the remuneration is paid by a non-resident employer, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State; remuneration for employment aboard enterprises operating in international traffic is taxable only in the enterprise's State.

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