Taxation of employment income: residence state generally taxed unless work performed abroad; limited exemption where presence is brief, employer non resident and no local PE burden. Article 15 provides that employment remuneration arising to a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exception preserves exclusive taxation by the resident State where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that other State. Remuneration for employment on ships or aircraft in international traffic may be taxed in the State where the operating enterprise is based.
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Provisions expressly mentioned in the judgment/order text.
Taxation of employment income: residence state generally taxed unless work performed abroad; limited exemption where presence is brief, employer non resident and no local PE burden.
Article 15 provides that employment remuneration arising to a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exception preserves exclusive taxation by the resident State where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that other State. Remuneration for employment on ships or aircraft in international traffic may be taxed in the State where the operating enterprise is based.
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