Dependent personal services: employment income taxable in resident state unless exercised abroad, subject to short-term presence and employer residence conditions.

Remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax it. An exception confines taxation to the resident State where the employee's presence in the other State is limited to a specified short term aggregate period, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there; employment on ships or aircraft in international traffic may be taxed in the enterprise's State.

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