Dependent personal services: employment income taxed where duties are performed, subject to presence, employer and permanent establishment conditions.

Remuneration from employment is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. However, taxation is confined to the State of residence if the employee's presence in the other State does not exceed the applicable presence threshold, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that State. Remuneration for service aboard ships or aircraft in international traffic may be taxed in the State of residence of the enterprise operating them.

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