Taxation of Employment Income: residence-based taxation with place-of-work exception and a short-term presence exemption for cross-border workers. Salaries, wages and similar remuneration derived by a resident of a Contracting State are taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration; however, a short-term presence exemption applies where the worker is present only for a limited period, the employer is not resident in the other State and the remuneration is not borne by a permanent establishment or fixed base there, and remuneration for employment aboard a ship or aircraft in international traffic is taxable only in the enterprise's resident 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: residence-based taxation with place-of-work exception and a short-term presence exemption for cross-border workers.
Salaries, wages and similar remuneration derived by a resident of a Contracting State are taxable only in that State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration; however, a short-term presence exemption applies where the worker is present only for a limited period, the employer is not resident in the other State and the remuneration is not borne by a permanent establishment or fixed base there, and remuneration for employment aboard a ship or aircraft in international traffic is taxable only in the enterprise's resident State.
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