Dependent personal services: employment income taxed in resident state unless exercised abroad; limited presence and non resident employer can exempt. Article 15 treats salaries and similar remuneration as taxable in the taxpayer's State of residence unless the employment is exercised in the other State, in which case that other State may tax the remuneration. An exemption prevents taxation in the State where the employment is exercised if the individual's presence there is of limited duration, the payor is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer; remuneration from employment aboard ships or aircraft in international traffic may be taxed by the State of the enterprise.
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 taxed in resident state unless exercised abroad; limited presence and non resident employer can exempt.
Article 15 treats salaries and similar remuneration as taxable in the taxpayer's State of residence unless the employment is exercised in the other State, in which case that other State may tax the remuneration. An exemption prevents taxation in the State where the employment is exercised if the individual's presence there is of limited duration, the payor is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer; remuneration from employment aboard ships or aircraft in international traffic may be taxed by the State of the enterprise.
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