Dependent personal services: residence-based taxation with a limited presence exemption and permanent establishment condition. Article 15 provides that remuneration derived by a resident is taxable only in the resident State unless employment is exercised in the other State, in which case that State may tax the remuneration. A three-part limited presence exemption makes such remuneration taxable only in the resident State where the recipient's presence in the other State is limited, the payor is not resident in the 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 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 services: residence-based taxation with a limited presence exemption and permanent establishment condition.
Article 15 provides that remuneration derived by a resident is taxable only in the resident State unless employment is exercised in the other State, in which case that State may tax the remuneration. A three-part limited presence exemption makes such remuneration taxable only in the resident State where the recipient's presence in the other State is limited, the payor is not resident in the 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 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 
