Employment income residency rule limits taxation where presence, payer residence, and permanent establishment conditions are met. Remuneration derived by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax it. However, such remuneration is taxable only in the resident State if the employee's presence in the other State falls below the specified aggregate presence threshold for the relevant twelve-month periods, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment there. Wages of regular complement of ships or aircraft in international traffic remain taxable only in the State of residence.
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.
Employment income residency rule limits taxation where presence, payer residence, and permanent establishment conditions are met.
Remuneration derived by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax it. However, such remuneration is taxable only in the resident State if the employee's presence in the other State falls below the specified aggregate presence threshold for the relevant twelve-month periods, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment there. Wages of regular complement of ships or aircraft in international traffic remain taxable only in the State of residence.
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