Dependent personal services: employment income generally taxed in the worker's residence unless treaty exceptions permit source-state taxation. Article 15 provides that remuneration of a resident for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State; if exercised there the other State may tax that remuneration. An exception preserves residence-state taxation where the worker's presence in the other State is limited, the payer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in the other State. Remuneration for employment 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: employment income generally taxed in the worker's residence unless treaty exceptions permit source-state taxation.
Article 15 provides that remuneration of a resident for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State; if exercised there the other State may tax that remuneration. An exception preserves residence-state taxation where the worker's presence in the other State is limited, the payer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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