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<h1>Employment Income Taxation Across Borders: Navigating Double Tax Avoidance Rules with Residence, Duration, and Source Criteria</h1> A statutory provision governing taxation of employment income in cross-border scenarios under a Double Tax Avoidance Agreement. The conditions for taxation of dependent personal services, specifying that employment income is generally taxable in the employee's resident state. Exceptions exist when employment is exercised in another state, subject to specific conditions like duration of stay (183 days), payment source, and absence of permanent establishment. Special provisions apply for maritime and aviation professionals working in international transit.