Dependent personal service taxation: resident state generally taxes employment income unless work is exercised abroad, subject to short term presence and employer residency exceptions. Article 15 provides that employment remuneration derived by a resident is taxable only in that State unless the employment is exercised in the other Contracting State, in which case the other State may tax such remuneration. An exception preserves exclusive taxation by the resident State where the worker's presence in the other State does not exceed an aggregate 183 days in a twelve month period, the payor 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 service aboard ships or aircraft in international traffic may be taxed by the operating enterprise's State.