Short-term presence exemption for employment income limits taxation to the resident State when specified employer and permanent establishment conditions apply. Salaries, wages and similar remuneration of a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, exclusive taxation by the resident State applies where the employee's presence in the other State is temporary (short-term presence exemption), the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there; remuneration from employment aboard internationally operated ships or aircraft is taxable in the resident 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.
Short-term presence exemption for employment income limits taxation to the resident State when specified employer and permanent establishment conditions apply.
Salaries, wages and similar remuneration of a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, exclusive taxation by the resident State applies where the employee's presence in the other State is temporary (short-term presence exemption), the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there; remuneration from employment aboard internationally operated ships or aircraft is taxable in the resident State.
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