Dependent personal services: income taxed in resident state unless exercised abroad; short-term presence and employer residence can limit taxation to resident state.

Dependent personal services income is taxable in the individual's State of residence unless the employment is exercised in the other Contracting State, in which case income from that exercise may be taxed there. However, income is taxable only in the resident State where the individual's presence in the other State does not exceed a short-term presence threshold, remuneration is paid by an employer who is not resident in the other State, and the remuneration is not deductible for a permanent establishment or fixed base of the employer in the other State.

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