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 ... Summary
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.
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