Dependent personal services: taxation generally in resident State unless employment exercised abroad; exceptions for short presence and nonresident employer.

Salaries, wages and similar remuneration of a resident for employment are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exemption applies where the employee's presence in the other State is of short aggregate duration, the remuneration is paid by or on behalf of an employer who is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of residence.

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