Taxation of employment income: resident state taxes salary unless employment is exercised abroad and presence threshold applies. Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, if three cumulative conditions are met - limited presence in the other State, payment by an employer not resident in the other State, and remuneration not borne by a permanent establishment or fixed base there - the remuneration remains taxable only in the State of residence. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State of residence.
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.
Taxation of employment income: resident state taxes salary unless employment is exercised abroad and presence threshold applies.
Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, if three cumulative conditions are met - limited presence in the other State, payment by an employer not resident in the other State, and remuneration not borne by a permanent establishment or fixed base there - the remuneration remains taxable only in the State of residence. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State of residence.
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