Taxation of employment income: residence state taxation unless services exercised abroad, with presence and payor conditions.

Article 16 provides that remuneration for dependent personal services is taxable only in the resident State unless the employment is exercised in the other Contracting State; if exercised there, that State may tax the remuneration. An exception prevents source state taxation when the employee's presence is limited, the payor is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base of the employer. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of the enterprise's place of effective management.

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