Taxation of employment income: primary taxing right lies with residence unless employment is exercised abroad with exceptions.

Article 15 provides that employment remuneration is generally taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Remuneration remains taxable only in the resident State where the employee's aggregate presence in the other State does not exceed a short-term presence test, the payer is not a resident of the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in the other State. Remuneration for service on ships or aircraft in international traffic may be taxed by the enterprise's State.

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