Taxation of employment income: resident state generally taxes salaries unless employment is exercised abroad, subject to presence thresholds. Dependent personal services income is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration; however, taxation is confined to the resident State where presence in the other State does not exceed the prescribed aggregate threshold, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there.
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 generally taxes salaries unless employment is exercised abroad, subject to presence thresholds.
Dependent personal services income is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration; however, taxation is confined to the resident State where presence in the other State does not exceed the prescribed aggregate threshold, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
