Dependent personal services: taxation in resident territory unless employment exercised abroad; limited-presence exception with employer and PE conditions. Article 15 provides that remuneration for employment by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration. However, remuneration earned in the other State shall be taxable only in the State of residence where the employee's presence in the other State does not exceed in the aggregate 183 days in any twelve-month period, the payor is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other 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 in resident territory unless employment exercised abroad; limited-presence exception with employer and PE conditions.
Article 15 provides that remuneration for employment by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration. However, remuneration earned in the other State shall be taxable only in the State of residence where the employee's presence in the other State does not exceed in the aggregate 183 days in any twelve-month period, the payor is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State.
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