Dependent Personal Services: allocation of taxing rights between residence and source states, with exceptions for short-term presence and employer residency. Remuneration by a resident is taxable in the resident State unless employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception bars source-state taxation where the employee's presence is limited to short-term stays not exceeding 183 days, the payer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base there.
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Provisions expressly mentioned in the judgment/order text.
Dependent Personal Services: allocation of taxing rights between residence and source states, with exceptions for short-term presence and employer residency.
Remuneration by a resident is taxable in the resident State unless employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception bars source-state taxation where the employee's presence is limited to short-term stays not exceeding 183 days, the payer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base there.
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