Dependent personal services tax allocation: place of employment governs taxation, with narrow short term and employer borne exceptions.

Salaries, wages and similar remuneration paid to a resident for employment are taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax the remuneration. An exception preserves taxation in the resident State where the presence in the other State is limited by short term engagement, the employer is not resident in the other State and does not hire out labour, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for employment aboard ships or aircraft in international traffic is taxable in the enterprise's State of residence.

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