Taxation of employment income: resident state retains taxing right when foreign exercise is limited and employer is non-resident. Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other State; if so exercised, the other State may tax such remuneration. Resident-state taxation remains exclusive where presence in the other State is limited, the employer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships 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: resident state retains taxing right when foreign exercise is limited and employer is non-resident.
Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other State; if so exercised, the other State may tax such remuneration. Resident-state taxation remains exclusive where presence in the other State is limited, the employer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's 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 
