Taxation of employment income: residence state rule, with limited-presence exception and employer/residence conditions. Remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. Exclusive taxation by the residence State applies if the worker's presence in the other State is limited, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there.
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 state rule, with limited-presence exception and employer/residence conditions.
Remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. Exclusive taxation by the residence State applies if the worker's presence in the other State is limited, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there.
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