Dependent personal services: employment income taxed in residence unless source-state taxation applies under specific presence and employer conditions. 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 State may tax it. However, such cross-border remuneration is taxable solely in the residence State where the employee's presence in the source State does not exceed an aggregate of 183 days in any twelve-month period, the payer is not a resident of the source State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration from employment on ships or aircraft in international traffic may be taxed in the enterprise'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: employment income taxed in residence unless source-state taxation applies under specific presence and employer conditions.
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 State may tax it. However, such cross-border remuneration is taxable solely in the residence State where the employee's presence in the source State does not exceed an aggregate of 183 days in any twelve-month period, the payer is not a resident of the source State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration from employment on ships or aircraft in international traffic may be taxed in the enterprise's State.
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