Dependent personal services: employment remuneration taxed in resident State unless services are exercised abroad, with limited exceptions. Article 16 provides that remuneration from employment of a resident is generally taxable only in the resident State, but may be taxed in the State where the employment is exercised. Remuneration exercised in the other State remains taxable only in the resident State if the employee's presence does not exceed the relevant 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 from employment aboard ships or aircraft in international traffic by an enterprise of a Party is taxable only in that Party.