Dependent Personal Services: residence-state taxation generally, source-state taxation if employment is exercised there under specified conditions.

Article 16 provides that employment remuneration of a resident is taxable only in the resident State unless the employment is exercised in the other Contracting State, where it may also be taxed. An exception preserves exclusive taxation by the resident State when the employee's presence in the other State is limited, the payor is not resident in that other State, and the pay is not borne by a permanent establishment or fixed base there. Remuneration for service aboard ships or aircraft in international traffic may be taxed in the enterprise's State of residence.

---

---

---