Dependent personal services: taxation limited to resident state unless employment exercised abroad; presence threshold and employer non residency exceptions apply. Employment remuneration is taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, such remuneration is taxable only in the State of residence where the employee's presence in the other State stays within a specified aggregate threshold period, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for service 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.
Dependent personal services: taxation limited to resident state unless employment exercised abroad; presence threshold and employer non residency exceptions apply.
Employment remuneration is taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, such remuneration is taxable only in the State of residence where the employee's presence in the other State stays within a specified aggregate threshold period, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for service aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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