Taxation of employment income: residence-based taxation subject to presence, employer residence, and permanent establishment tests. Salaries, wages and similar remuneration paid to a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State. Remuneration exercised in the other State is taxable only in the resident State if the employee's presence in the other State does not exceed the treaty's temporal threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration from employment aboard a ship 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.
Taxation of employment income: residence-based taxation subject to presence, employer residence, and permanent establishment tests.
Salaries, wages and similar remuneration paid to a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State. Remuneration exercised in the other State is taxable only in the resident State if the employee's presence in the other State does not exceed the treaty's temporal threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration from employment aboard a ship or aircraft in international traffic may be taxed in the enterprise's State.
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