Dependent personal services: residence-based taxation, but cross-border employment taxable in source state if presence, employer residence and PE conditions met. Salaries, wages and similar remuneration paid to a resident are taxable only in the state of residence unless the employment is exercised in the other Contracting State, in which case that remuneration may be taxed in the other State. Notwithstanding this, remuneration for employment exercised in the other State is taxable only in the state of residence if three conditions are met: a presence threshold in the other State, payment by or on behalf of an employer 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 for employment aboard ships or aircraft in international traffic may be taxed in the State 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: residence-based taxation, but cross-border employment taxable in source state if presence, employer residence and PE conditions met.
Salaries, wages and similar remuneration paid to a resident are taxable only in the state of residence unless the employment is exercised in the other Contracting State, in which case that remuneration may be taxed in the other State. Notwithstanding this, remuneration for employment exercised in the other State is taxable only in the state of residence if three conditions are met: a presence threshold in the other State, payment by or on behalf of an employer 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 for employment aboard ships or aircraft in international traffic may be taxed in the State of the operating enterprise.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
