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.

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