Dependent personal services: employment income taxed in resident state unless exercised abroad with limited presence and non-resident employer. Remuneration for dependent personal services is taxable in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exemption applies if the employee's presence in the other State is limited, the employer is not resident there, and the pay is not borne by a permanent establishment or fixed base of the employer in that State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's 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.
Dependent personal services: employment income taxed in resident state unless exercised abroad with limited presence and non-resident employer.
Remuneration for dependent personal services is taxable in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exemption applies if the employee's presence in the other State is limited, the employer is not resident there, and the pay is not borne by a permanent establishment or fixed base of the employer in that State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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