Dependent personal services taxable in resident state unless employment exercised abroad; exemption requires limited presence and nonresident employer. Article 15 provides that remuneration for dependent personal services is taxable only in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exemption applies where the individual has only a limited presence in the other State, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base; remuneration from employment aboard ships or aircraft in international traffic may be taxed by 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 taxable in resident state unless employment exercised abroad; exemption requires limited presence and nonresident employer.
Article 15 provides that remuneration for dependent personal services is taxable only in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exemption applies where the individual has only a limited presence in the other State, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base; remuneration from employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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 
