Dependent personal services: resident-state taxation generally applies unless work abroad triggers source-state taxation subject to a presence threshold. Article 15 provides that remuneration from dependent personal services is taxable only in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, such source-state taxation is excluded if the worker's presence in the other State does not exceed a specified presence threshold, the payer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's Contracting 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: resident-state taxation generally applies unless work abroad triggers source-state taxation subject to a presence threshold.
Article 15 provides that remuneration from dependent personal services is taxable only in the resident Contracting State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, such source-state taxation is excluded if the worker's presence in the other State does not exceed a specified presence threshold, the payer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's Contracting State.
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