Dependent personal services: remuneration taxed in resident state unless exercised abroad; presence, employer residency and PE allocation affect taxing rights.

Dependent personal services income is taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, where it may be taxed. However, such remuneration is taxable only in the resident State if the employee's presence in the other State does not exceed an aggregate threshold within twelve months, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in that other State. Remuneration for employment aboard international ships or aircraft may be taxed in the operating enterprise's State.

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