Taxation of employment income: source-state may tax work performed there unless presence is short and employer/PE conditions met. Article 15 allocates taxing rights for employment income: residents' salaries are generally taxable in the State of residence unless the employment is exercised in the other State, where the income may be taxed. An exemption applies when the employee's presence in the other State is of limited duration, the remuneration is paid by an employer not resident in that State, and the payment is not borne by a permanent establishment there. Remuneration of regular crew on ships or aircraft in international traffic is taxable only in the State of residence except for operations solely within the other 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.
Taxation of employment income: source-state may tax work performed there unless presence is short and employer/PE conditions met.
Article 15 allocates taxing rights for employment income: residents' salaries are generally taxable in the State of residence unless the employment is exercised in the other State, where the income may be taxed. An exemption applies when the employee's presence in the other State is of limited duration, the remuneration is paid by an employer not resident in that State, and the payment is not borne by a permanent establishment there. Remuneration of regular crew on ships or aircraft in international traffic is taxable only in the State of residence except for operations solely within the other State.
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