Taxation of employment income: source-state taxation possible when work is performed there unless limited presence and nonresident employer. Article 16 allocates taxing rights for Dependent Personal Services: remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exclusion applies where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's 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.
Taxation of employment income: source-state taxation possible when work is performed there unless limited presence and nonresident employer.
Article 16 allocates taxing rights for Dependent Personal Services: remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exclusion applies where the employee's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the enterprise's State.
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