Dependent personal services: employment income taxable in residence unless exercised abroad; specific presence and employer conditions may preserve residence taxation. Remuneration for dependent personal services is taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax such remuneration. Exclusive taxation in the resident State applies when the recipient's presence in the other State does not exceed an aggregate 183 days in any twelve-month period, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for service aboard internationally operated ships or aircraft 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 taxable in residence unless exercised abroad; specific presence and employer conditions may preserve residence taxation.
Remuneration for dependent personal services is taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax such remuneration. Exclusive taxation in the resident State applies when the recipient's presence in the other State does not exceed an aggregate 183 days in any twelve-month period, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for service aboard internationally operated ships or aircraft may be taxed in the enterprise's State.
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