Dependent personal services: salaries taxed in resident state; foreign employment taxable if exercised abroad, subject to presence and employer/PE conditions. Salaries and similar remuneration are taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration exercised in the other State is taxable only in the resident State if the recipient's presence in the other State falls below the specified 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 of the employer in that other State. Remuneration aboard ships or aircraft in international traffic may be taxed in the operating enterprise's State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dependent personal services: salaries taxed in resident state; foreign employment taxable if exercised abroad, subject to presence and employer/PE conditions.
Salaries and similar remuneration are taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration exercised in the other State is taxable only in the resident State if the recipient's presence in the other State falls below the specified 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 of the employer in that other State. Remuneration aboard ships or aircraft in international traffic may be taxed in the operating enterprise's State.
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