Dependent personal services taxation: residence-based tax applies unless employment is exercised abroad, subject to short term presence and employer conditions. Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State; however, remuneration for work exercised abroad remains taxable only in the residence State if the presence abroad is within a specified short-term threshold, the payor is not resident in the other State, and the remuneration is not charged to a permanent establishment in that other State. Remuneration for services aboard a ship or aircraft in international traffic is taxable only in the State of residence of the operating enterprise.
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: residence-based tax applies unless employment is exercised abroad, subject to short term presence and employer conditions.
Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State; however, remuneration for work exercised abroad remains taxable only in the residence State if the presence abroad is within a specified short-term threshold, the payor is not resident in the other State, and the remuneration is not charged to a permanent establishment in that other State. Remuneration for services aboard a ship or aircraft in international traffic is taxable only in the State of residence of the operating enterprise.
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