Dependent personal services: source taxation allowed when employment is exercised abroad unless short-term presence and nonresident employer conditions apply. Dependent personal services are taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration. An exemption prevents source-State taxation where three conditions coexist: short-term presence in the source State, remuneration paid by a nonresident employer, and compensation not borne by the employer's permanent establishment or fixed base in the source State; a separate rule allows taxation by the enterprise's State for employment aboard ships or aircraft in international traffic.
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: source taxation allowed when employment is exercised abroad unless short-term presence and nonresident employer conditions apply.
Dependent personal services are taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration. An exemption prevents source-State taxation where three conditions coexist: short-term presence in the source State, remuneration paid by a nonresident employer, and compensation not borne by the employer's permanent establishment or fixed base in the source State; a separate rule allows taxation by the enterprise's State for employment aboard ships or aircraft in international traffic.
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