Dependent personal services taxation may be allocated to the source state when employment is exercised there. Article 15 provides that remuneration for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case the other State may tax that remuneration. An exception applies where the recipient's presence in the other State does not exceed an aggregate period of 183 days within any twelve month period, the remuneration is paid by or on behalf of an employer who is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Employment aboard ships or aircraft in international traffic may be taxed in the 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 taxation may be allocated to the source state when employment is exercised there.
Article 15 provides that remuneration for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case the other State may tax that remuneration. An exception applies where the recipient's presence in the other State does not exceed an aggregate period of 183 days within any twelve month period, the remuneration is paid by or on behalf of an employer who is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Employment aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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