Dependent personal services taxation: residence-based rule with a limited presence exception and employer/PE conditions. Article 15 establishes that remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other State, in which case that other State may tax such remuneration. A limited presence exception prevents source-state taxation where the worker is present only for a short aggregate period, the payer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that State. Remuneration for employment on ships or aircraft in international traffic may be taxed where the enterprise's place of effective management is located.
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Provisions expressly mentioned in the judgment/order text.
Dependent personal services taxation: residence-based rule with a limited presence exception and employer/PE conditions.
Article 15 establishes that remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other State, in which case that other State may tax such remuneration. A limited presence exception prevents source-state taxation where the worker is present only for a short aggregate period, the payer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that State. Remuneration for employment on ships or aircraft in international traffic may be taxed where the enterprise's place of effective management is located.
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