Taxation of employment income: resident state generally taxes salaries unless services exercised abroad trigger taxation by the other state. Article 15 provides that resident-based taxation applies to employment remuneration unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exception applies where presence in the other State is limited by a short-term presence condition, the remuneration is paid by or on behalf of an employer not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State; these three conditions must all be satisfied for exclusive taxation by the resident State.
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.
Taxation of employment income: resident state generally taxes salaries unless services exercised abroad trigger taxation by the other state.
Article 15 provides that resident-based taxation applies to employment remuneration unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exception applies where presence in the other State is limited by a short-term presence condition, the remuneration is paid by or on behalf of an employer not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State; these three conditions must all be satisfied for exclusive taxation by the resident State.
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