Dependent personal services: employment income taxed where exercised unless short-term presence and employer conditions limit taxation to resident State.

Remuneration from dependent personal services is taxable only in the resident State unless the employment is exercised in the other State, in which case that State may tax the income. However, income is taxable only in the resident State if the employee's presence in the other State is within a short-term threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's State.

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