Dependent personal services: employment income taxable in residence but may be taxed where services are performed under specified conditions.

The DTAA provides that employment income is taxable primarily in the employee's State of residence but may be taxed in the State where the employment is exercised; however, source state taxation is excluded where presence in the other State is limited, the payer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base in that State.

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