Dependent personal services taxation: residence state retains primary taxing right unless employment is exercised abroad; limited exemption applies.

Remuneration of a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax it; however, where the worker's presence in the other State is short, the employer is not a resident of that other State, and the remuneration is not borne by a permanent establishment or fixed base there, the remuneration remains taxable only in the State of residence. Remuneration from employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.

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