Taxation of employment income: residence-state taxation generally applies; short-term presence exceptions limit source-state tax rights. Salaries, wages and similar remuneration for employment are taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, where the employee's presence in the other State does not exceed 183 days in any twelve month period, the remuneration is paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State, the remuneration is taxable only in the residence State. Remuneration for employment aboard ships or aircraft in international traffic is taxable 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.
Taxation of employment income: residence-state taxation generally applies; short-term presence exceptions limit source-state tax rights.
Salaries, wages and similar remuneration for employment are taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, where the employee's presence in the other State does not exceed 183 days in any twelve month period, the remuneration is paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State, the remuneration is taxable only in the residence State. Remuneration for employment aboard ships or aircraft in international traffic is taxable in the enterprise's State.
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