Dependent personal services: short-term presence and employer residence rules determine which state may tax employment remuneration.

Remuneration for dependent personal services is generally taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Exclusive taxation by the residence State applies where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed by the residence State.

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