Dependent personal services: employment income taxed by residence unless exercised abroad, subject to presence and employer conditions. Remuneration for employment is taxable in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, employment income exercised in the other State is taxable only in the resident State if the worker's presence in the other State falls below a limited presence threshold for the fiscal year, the payor is not resident in the other State, and the pay is not borne by a permanent establishment or fixed base there. Income from employment aboard ships or aircraft in international traffic may be taxed where the enterprise's place of effective management is located.
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.
Dependent personal services: employment income taxed by residence unless exercised abroad, subject to presence and employer conditions.
Remuneration for employment is taxable in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, employment income exercised in the other State is taxable only in the resident State if the worker's presence in the other State falls below a limited presence threshold for the fiscal year, the payor is not resident in the other State, and the pay is not borne by a permanent establishment or fixed base there. Income from employment aboard ships or aircraft in international traffic may be taxed where the enterprise's place of effective management is located.
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