Dependent personal services taxation limited to residence unless employment exercised abroad; short-term presence and non-resident employer exceptions apply.

Dependent personal services income paid to a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, taxation remains in the resident State where presence abroad is limited, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there.

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