Dependent personal services under the Brazil tax treaty allocate employment income between residence and source States with specific exemptions. Salaries, wages and similar remuneration from employment are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case the remuneration may also be taxed there. Remuneration remains taxable only in the first-mentioned State if the employee is present in the other State for not more than 183 days in the relevant period, the employer is not a resident of that State, and the remuneration is not borne by a permanent establishment or fixed base there. Special treatment applies to crew on ships or aircraft in international traffic.