Dependent personal services: residence-based taxation generally applies, with limited exceptions where employment is exercised abroad.

Article 15 provides that remuneration from employment is generally taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. Exclusive taxation by the resident State applies where the employee's presence in the other State is limited, the employer is not resident in the other State, and the remuneration is not borne by an employer's permanent establishment or fixed base in the other State; remuneration for service on ships or aircraft in international traffic may be taxed in the enterprise's State.

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