Dependent Personal Services: limited presence and employer residence conditions can keep employment income taxable only in the home state. Article 15 provides that employment remuneration is taxable 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 taxation solely in the resident State when the worker's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by 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: limited presence and employer residence conditions can keep employment income taxable only in the home state.
Article 15 provides that employment remuneration is taxable 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 taxation solely in the resident State when the worker's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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