Dependent personal services: employment income taxable in resident state unless work is exercised abroad with specific exceptions. Article 15 allocates taxing rights over remuneration for employment: employment income of a resident is taxable only in the resident State unless the employment is exercised in the other State. An exception keeps such income taxable only in the resident State if three conditions are met: limited presence in the other State within the fiscal year, payment by or on behalf of an employer not resident in the other State, and that the remuneration is not borne by a permanent establishment or fixed base there. Income from employment aboard ships or aircraft in international traffic remains taxable only in the resident 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: employment income taxable in resident state unless work is exercised abroad with specific exceptions.
Article 15 allocates taxing rights over remuneration for employment: employment income of a resident is taxable only in the resident State unless the employment is exercised in the other State. An exception keeps such income taxable only in the resident State if three conditions are met: limited presence in the other State within the fiscal year, payment by or on behalf of an employer not resident in the other State, and that the remuneration is not borne by a permanent establishment or fixed base there. Income from employment aboard ships or aircraft in international traffic remains taxable only in the resident State.
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