Dependent personal services: taxed in resident State unless exercised abroad; short-term presence, nonresident employer and no local PE exempt.

Article 16 provides that remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other Contracting State, in which case that State may tax the remuneration. A three-part exception confines taxation to the resident State where the presence in the other State is short-term, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in the other State. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the State of the enterprise's place of effective management.

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