Dependent personal services: employment income taxable in resident state unless exercised abroad; limited presence and employer conditions create exceptions. Remuneration of a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State; however, where the recipient's presence in the other State is limited by a short-term presence rule, the payor is not resident in the other State, and the remuneration is not charged to a permanent establishment or fixed base there, the remuneration remains taxable solely in the State of residence. Remuneration for service aboard ships or aircraft in international traffic by an enterprise of a Contracting State is taxable in that 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: employment income taxable in resident state unless exercised abroad; limited presence and employer conditions create exceptions.
Remuneration of a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State; however, where the recipient's presence in the other State is limited by a short-term presence rule, the payor is not resident in the other State, and the remuneration is not charged to a permanent establishment or fixed base there, the remuneration remains taxable solely in the State of residence. Remuneration for service aboard ships or aircraft in international traffic by an enterprise of a Contracting State is taxable in that State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
