Taxation of employment income: residence state taxation applies unless employment is exercised abroad and local taxing conditions are met. Salaries, wages and similar remuneration of a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case the remuneration may be taxed there. However, remuneration for employment exercised in the other State is taxable only in the resident State if three conditions are met: the individual's presence in the other State does not exceed the specified aggregate period in a twelve month period; the remuneration is paid by or on behalf of an employer not resident in the other State; and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State.
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Provisions expressly mentioned in the judgment/order text.
Taxation of employment income: residence state taxation applies unless employment is exercised abroad and local taxing conditions are met.
Salaries, wages and similar remuneration of a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case the remuneration may be taxed there. However, remuneration for employment exercised in the other State is taxable only in the resident State if three conditions are met: the individual's presence in the other State does not exceed the specified aggregate period in a twelve month period; the remuneration is paid by or on behalf of an employer not resident in the other State; and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State.
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