Dependent personal services: taxation is residence-based, with limited foreign taxation when presence is brief, employer nonresident, and no PE. Salaries, wages and similar remuneration under Dependent personal services are taxable only 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. Exclusive residence-State taxation applies where the employee's aggregate presence in the other State is limited, the remuneration is paid by or on behalf of a nonresident employer, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration for employment aboard ships or aircraft in international traffic is taxed only in the State of the enterprise's place of effective management.