Dependent personal services taxation: remuneration taxable in resident state unless employment is exercised in the other state. Article 16 provides that remuneration for dependent personal services is generally taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax the pay. The Article preserves taxation in the resident State where a short-term presence exception applies, where the employer is not resident in the other State, or where the remuneration is not borne by a permanent establishment or fixed base in the other State; it separately addresses international transport by ship or aircraft.
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 taxation: remuneration taxable in resident state unless employment is exercised in the other state.
Article 16 provides that remuneration for dependent personal services is generally taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax the pay. The Article preserves taxation in the resident State where a short-term presence exception applies, where the employer is not resident in the other State, or where the remuneration is not borne by a permanent establishment or fixed base in the other State; it separately addresses international transport by ship or aircraft.
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