Taxation of employment income: resident State generally taxes, with limited source state rights when services are performed abroad. Remuneration for employment 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 such income. However, where the worker's presence in the other State falls below a short-term presence threshold, the pay is made by an employer not resident in that other State, and the pay is not deductible against a permanent establishment or fixed base of the employer there, taxation is confined to the resident State. Remuneration aboard 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: resident State generally taxes, with limited source state rights when services are performed abroad.
Remuneration for employment 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 such income. However, where the worker's presence in the other State falls below a short-term presence threshold, the pay is made by an employer not resident in that other State, and the pay is not deductible against a permanent establishment or fixed base of the employer there, taxation is confined to the resident State. Remuneration aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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