Dependent personal services: residence-based taxation generally applies unless work is exercised abroad, with limited presence exceptions. Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax it. However, remuneration for employment exercised in the other State is taxable only in the residence state if the employee's presence in the other State does not exceed an aggregate 183-day period in the relevant tax year, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration from employment aboard an international ship or aircraft operated by an enterprise of a Contracting State is taxable only in that 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: residence-based taxation generally applies unless work is exercised abroad, with limited presence exceptions.
Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax it. However, remuneration for employment exercised in the other State is taxable only in the residence state if the employee's presence in the other State does not exceed an aggregate 183-day period in the relevant tax year, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration from employment aboard an international ship or aircraft operated by an enterprise of a Contracting State is taxable only in that State.
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