Dependent personal service taxation: employment income generally taxed in residence state unless taxed where services are performed.

Remuneration from employment is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, where it may be taxed. However, remuneration for employment exercised in the other State is taxable only in the resident State if the employee's presence in the other State does not exceed the prescribed physical presence threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State. Remuneration for service aboard international ships or aircraft may be taxed in the State of the enterprise.

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