Taxation of employment income: residence-based rule allows source-State taxation when employment is exercised there, with short-term exemption. Article 15 establishes that employment income of a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception confines source-State taxation where three conditions coincide: the employee's presence in the source State is limited, the employer is not resident in the source State, and the remuneration is not deductible against profits of a permanent establishment or fixed base of the employer in the source State. Remuneration aboard ships or aircraft in international traffic may be taxed by the State of the operating enterprise.
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-based rule allows source-State taxation when employment is exercised there, with short-term exemption.
Article 15 establishes that employment income of a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception confines source-State taxation where three conditions coincide: the employee's presence in the source State is limited, the employer is not resident in the source State, and the remuneration is not deductible against profits of a permanent establishment or fixed base of the employer in the source State. Remuneration aboard ships or aircraft in international traffic may be taxed by the State of the operating enterprise.
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