Dependent personal services: residency-based taxation generally, but source-state taxation arises if employment is exercised there under presence and employer conditions.

Dependent personal services remuneration is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax it. Source-state taxation is excluded where presence in the source State is limited, the employer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base of the employer there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the State of the operating enterprise.

---

---

---