Taxation of employment income: residence state generally taxes, with short term presence and employer/permanent establishment exceptions for cross border workers.

Article 15 provides that employment remuneration is taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, where it may be taxed; however, where presence in the other State is short term, the payor is non resident there, and the remuneration is not borne by a permanent establishment or fixed base in that State, taxation remains in the residence State; remuneration from employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.

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