Dependent personal services rule: employment income taxed in residence unless exercised abroad, subject to temporary presence conditions. Article 15 provides that employment income is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration. An exception prevents source-state taxation where the employee's presence in the other State does not exceed an aggregate of 183 days in a relevant twelve month period, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there; remuneration from employment aboard ships or aircraft in international traffic may be taxed in the employer's 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 rule: employment income taxed in residence unless exercised abroad, subject to temporary presence conditions.
Article 15 provides that employment income is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration. An exception prevents source-state taxation where the employee's presence in the other State does not exceed an aggregate of 183 days in a relevant twelve month period, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there; remuneration from employment aboard ships or aircraft in international traffic may be taxed in the employer's State.
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