Article 15 - Dependent personal services

Dependent personal services: taxable in resident state unless exercised in source state; short-stay and non-resident employer exceptions apply.

Article 15 provides that salaries and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration. An exemption applies where the employee's presence in the other State is limited, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard a ship or aircraft in international traffic is taxable only in the State of the operating enterprise.