Dependent personal services: resident state generally taxes employment income unless employment is exercised in the other state, subject to exceptions. Article 15 allocates taxing rights over employment income to the employee's state of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration exercised in the other State remains taxable only in the resident state where the employee's presence in the other State falls below a short-term presence threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's state.
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Provisions expressly mentioned in the judgment/order text.
Dependent personal services: resident state generally taxes employment income unless employment is exercised in the other state, subject to exceptions.
Article 15 allocates taxing rights over employment income to the employee's state of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration exercised in the other State remains taxable only in the resident state where the employee's presence in the other State falls below a short-term presence threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's state.
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