Taxation of employment income: residence-based taxation with source-state taxing rights when employment is exercised abroad under DTAA. Remuneration derived by a resident of a Contracting State is taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax it; reciprocal exemptions apply where the employee's presence in the source State is limited, the payor is a non-resident employer, and the remuneration is not deductible against profits taxable in the source State; remuneration for employment aboard ships or aircraft in international traffic may be taxed in the State of residence of the person deriving profits from operation.
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Provisions expressly mentioned in the judgment/order text.
Taxation of employment income: residence-based taxation with source-state taxing rights when employment is exercised abroad under DTAA.
Remuneration derived by a resident of a Contracting State is taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax it; reciprocal exemptions apply where the employee's presence in the source State is limited, the payor is a non-resident employer, and the remuneration is not deductible against profits taxable in the source State; remuneration for employment aboard ships or aircraft in international traffic may be taxed in the State of residence of the person deriving profits from operation.
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