Dependent personal services tax allocation: presence, employer residency and cost-bearing determine which state may tax employment remuneration.

Article 15 allocates taxation of remuneration for dependent personal services primarily to the employee's State of residence unless the employment is exercised in the other Contracting State, which may then tax the income; however, where the employee's presence in the other State is of limited duration, the employer is not resident there and the remuneration is not borne by the employer's permanent establishment or fixed base in that State, taxation remains with the residence State. Remuneration for employment on ships or aircraft in international traffic may be taxed by the enterprise's State.

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