Dependent personal services: residency generally governs taxation, with limited exceptions when employment is exercised abroad. Dependent personal services remuneration is taxable only in the resident State unless the employment is exercised in the other Contracting State, where that other State may tax such remuneration. However, if three conditions are satisfied-presence in the other State does not exceed a specified aggregate time threshold in a relevant twelve month period; the payor is not resident in the other State; and the remuneration is not borne by a resident, permanent establishment, fixed base, or independent personal services provider in the other State-then taxation is confined to the resident State. Remuneration aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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: residency generally governs taxation, with limited exceptions when employment is exercised abroad.
Dependent personal services remuneration is taxable only in the resident State unless the employment is exercised in the other Contracting State, where that other State may tax such remuneration. However, if three conditions are satisfied-presence in the other State does not exceed a specified aggregate time threshold in a relevant twelve month period; the payor is not resident in the other State; and the remuneration is not borne by a resident, permanent establishment, fixed base, or independent personal services provider in the other State-then taxation is confined to the resident State. Remuneration aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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