Dependent personal services: remuneration taxed in the employee's residence state unless employment is exercised abroad with limited exceptions. Article 15 allocates taxing rights over remuneration from employment primarily to the employee's State of residence, except where the employment is exercised in the other Contracting State. Source-state taxation is limited if three conditions are met: the employee's presence in the source State is below a short-term threshold, the payer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base there; remuneration for international maritime or air services may be taxed at the place of effective management.
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: remuneration taxed in the employee's residence state unless employment is exercised abroad with limited exceptions.
Article 15 allocates taxing rights over remuneration from employment primarily to the employee's State of residence, except where the employment is exercised in the other Contracting State. Source-state taxation is limited if three conditions are met: the employee's presence in the source State is below a short-term threshold, the payer is not resident in the source State, and the remuneration is not borne by the employer's permanent establishment or fixed base there; remuneration for international maritime or air services may be taxed at the place of effective management.
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