Dependent personal services: taxation generally in resident state unless employment exercised abroad; limited presence and employer/PE conditions apply. Remuneration of a resident for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax it; however, exclusive taxation in the resident State applies where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by 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: taxation generally in resident state unless employment exercised abroad; limited presence and employer/PE conditions apply.
Remuneration of a resident for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax it; however, exclusive taxation in the resident State applies where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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