Dependent personal services taxation: resident-state taxation generally, with limited source-state taxation when employment is exercised abroad. Article 16 provides that remuneration for employment of a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exception limits taxation to the resident State where the employee is present in the other State for not more than 183 days in any twelve month period, the payor is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State; special rules apply to ships and aircraft in international traffic.