Dependent personal services tax rule: residence-based taxation subject to presence, employer residency and permanent establishment conditions.

Remuneration from employment is taxable primarily in the employee's State of residence, but may be taxed in the State where the employment is exercised. Exclusive taxation in the State of residence applies if the employee's presence in the other State does not exceed a limited presence threshold in any relevant twelve-month period, the payor is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer. Remuneration aboard ships or aircraft in international traffic may be taxed in the enterprise's State.

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