Taxation of employment income: residence-state taxation unless exercised abroad, with limited short-term presence exception.

Remuneration paid to a resident is taxable only in the residence State unless the employment is exercised in the other State, in which case that other State may tax the remuneration. An exception confines taxation to the residence State if presence in the other State is limited, the remuneration is paid by an employer 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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