Dependent personal services: income taxed in resident state unless exercised abroad, subject to presence, employer residency and PE tests.

Dependent personal services income is taxable in the recipient's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax remuneration derived therefrom. However, such remuneration is taxable only in the resident State where the presence test is met, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration from employment aboard ships or aircraft in international traffic may be taxed in the State of the operating enterprise.

---

---

---