Dependent personal services: presence, employer-residence and permanent-establishment conditions determine which state may tax employment remuneration. Article 15 provides that remuneration for dependent personal services paid to a resident is taxable only in the state of residence unless the employment is exercised in the other state. If exercised in the other state, that other state may tax the remuneration, except where three conditions are met-limited presence, payment by an employer not resident in the other state, and that the remuneration is not borne by a permanent establishment or fixed base-whereupon taxation remains in the state of residence; remuneration from 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: presence, employer-residence and permanent-establishment conditions determine which state may tax employment remuneration.
Article 15 provides that remuneration for dependent personal services paid to a resident is taxable only in the state of residence unless the employment is exercised in the other state. If exercised in the other state, that other state may tax the remuneration, except where three conditions are met-limited presence, payment by an employer not resident in the other state, and that the remuneration is not borne by a permanent establishment or fixed base-whereupon taxation remains in the state of residence; remuneration from employment aboard ships or aircraft in international traffic may be taxed in the enterprise's state.
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