Dependent personal services: remuneration generally taxed in resident state unless employment is exercised in the other state, subject to exceptions.

Dependent personal services taxation allocates taxing rights: remuneration of 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 it. A limited exception confines taxation to the residence State where short-term presence, nonresident employer payment, and absence of a permanent establishment bearing the remuneration all coexist. Remuneration for employment on ships or aircraft in international traffic is taxable in the State of the enterprise.

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