Dependent personal services: resident-state taxation generally applies, with source taxation only when employment is exercised abroad and thresholds met. Article 15 provides that remuneration for employment is taxable in the State of residence of the recipient unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, remuneration arising from employment exercised in the other State is taxable only in the resident State if: the employee's presence in the other State does not exceed a specified presence threshold in the relevant period; 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 from employment aboard ships or aircraft in international traffic is taxable only 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: resident-state taxation generally applies, with source taxation only when employment is exercised abroad and thresholds met.
Article 15 provides that remuneration for employment is taxable in the State of residence of the recipient unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, remuneration arising from employment exercised in the other State is taxable only in the resident State if: the employee's presence in the other State does not exceed a specified presence threshold in the relevant period; 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 from employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.
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