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.
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 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.
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 
