Taxation of employment income: short term presence, nonresident employer and no permanent establishment can limit source taxation. Salaries, wages and similar remuneration paid to a resident are taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration; however, source taxation is excluded where a treaty short term presence test is met, the payor is not resident in the source 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: short term presence, nonresident employer and no permanent establishment can limit source taxation.
Salaries, wages and similar remuneration paid to a resident are taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration; however, source taxation is excluded where a treaty short term presence test is met, the payor is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base there.
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