Taxation of employment income: generally taxed in the resident State unless duties abroad alter source-state taxing rights. Article 15 allocates taxation of remuneration for dependent personal services primarily to the resident State but allows the State where the employment is exercised to tax such remuneration. A short-stay exception prevents source-state taxation when the stay in the source State is limited, the employer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment on 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.
Taxation of employment income: generally taxed in the resident State unless duties abroad alter source-state taxing rights.
Article 15 allocates taxation of remuneration for dependent personal services primarily to the resident State but allows the State where the employment is exercised to tax such remuneration. A short-stay exception prevents source-state taxation when the stay in the source State is limited, the employer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's State.
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