Dependent personal services taxable in resident state unless exercised abroad; limited exceptions based on presence, employer residence and PE. Remuneration from employment is 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 it. However, remuneration for employment exercised abroad is taxable only in the resident State if the employee's presence abroad does not exceed the short term presence threshold, the employer is not a resident of the other State and is not in the business of hiring out labour, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Special rules apply to employment aboard ships or aircraft in international traffic.
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 exercised abroad; limited exceptions based on presence, employer residence and PE.
Remuneration from employment is 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 it. However, remuneration for employment exercised abroad is taxable only in the resident State if the employee's presence abroad does not exceed the short term presence threshold, the employer is not a resident of the other State and is not in the business of hiring out labour, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Special rules apply to employment aboard ships or aircraft in international traffic.
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