Dependent Personal Services: residence-based taxation generally applies unless employment is exercised in the other State, enabling source taxation. Taxation of employment income under the DTAA ordinarily resides with the taxpayer's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exception confines source taxation where the employee's presence in the other State does not exceed 183 days in the relevant twelve month period, the remuneration is paid by an employer not resident in the other State, and the remuneration is not charged to a permanent establishment or fixed base there; special rules apply to international shipping and aviation.
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: residence-based taxation generally applies unless employment is exercised in the other State, enabling source taxation.
Taxation of employment income under the DTAA ordinarily resides with the taxpayer's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exception confines source taxation where the employee's presence in the other State does not exceed 183 days in the relevant twelve month period, the remuneration is paid by an employer not resident in the other State, and the remuneration is not charged to a permanent establishment or fixed base there; special rules apply to international shipping and aviation.
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