Dependent personal services taxation: remuneration taxed in resident state unless employment is exercised abroad, subject to presence and employer conditions. Remuneration of a resident is taxable only in the State of residence unless employment is exercised in the other Contracting State, where such remuneration may be taxed; however, remuneration remains taxable only in the State of residence if the employee's presence in the other State is limited, the employer is not resident in that other State, and the pay is not borne by a permanent establishment or fixed base there. Remuneration from employment aboard ships or aircraft in international traffic may be taxed in the State of operation.
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: remuneration taxed in resident state unless employment is exercised abroad, subject to presence and employer conditions.
Remuneration of a resident is taxable only in the State of residence unless employment is exercised in the other Contracting State, where such remuneration may be taxed; however, remuneration remains taxable only in the State of residence if the employee's presence in the other State is limited, the employer is not resident in that other State, and the pay is not borne by a permanent establishment or fixed base there. Remuneration from employment aboard ships or aircraft in international traffic may be taxed in the State of operation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
