Dependent personal services: limited presence, nonresident employer and no permanent establishment keep taxation in the resident state.

Dependent personal services allocate taxation primarily to the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, remuneration is taxable only in the resident State if three conditions are met: limited presence in the other State, payment by or on behalf of a nonresident employer, and the remuneration is not borne by the employer's permanent establishment or fixed base in the other State. Remuneration from employment aboard a ship or aircraft in international traffic is taxable only in the enterprise's State.

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