Dependent personal services taxation: income taxable in resident state unless employment exercised abroad, subject to presence and employer/PE exceptions. Remuneration derived by a resident is generally taxable only in the resident State, but may be taxed in the other State if the employment is exercised there. Remuneration exercised in the other State remains taxable only in the resident State if three conditions are met: the recipient's presence in the other State does not exceed the prescribed presence threshold, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State. Remuneration for employment aboard ships or aircraft in international traffic is taxable 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 taxation: income taxable in resident state unless employment exercised abroad, subject to presence and employer/PE exceptions.
Remuneration derived by a resident is generally taxable only in the resident State, but may be taxed in the other State if the employment is exercised there. Remuneration exercised in the other State remains taxable only in the resident State if three conditions are met: the recipient's presence in the other State does not exceed the prescribed presence threshold, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State. Remuneration for employment aboard ships or aircraft in international traffic is taxable in the enterprise's State.
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