Dependent personal services: taxation follows residence unless employment is exercised abroad and employer conditions allow taxation there. Remuneration from employment is taxable 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, taxation remains in the State of residence where the employee's presence in the other State is within a short term presence threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for 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: taxation follows residence unless employment is exercised abroad and employer conditions allow taxation there.
Remuneration from employment is taxable 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, taxation remains in the State of residence where the employee's presence in the other State is within a short term presence threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's State.
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