Dependent personal services: employment income taxed in residence unless services are performed abroad with limited exceptions. Article 15 provides that remuneration from employment is taxable only in the recipient's resident State unless the employment is exercised in the other Contracting State, in which event that other State may tax the remuneration. A three-part exception preserves exclusive residence-state taxation where the recipient's presence in the other State does not exceed a specified presence threshold, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration of regular ship or aircraft crew on international traffic is taxable only in the resident 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: employment income taxed in residence unless services are performed abroad with limited exceptions.
Article 15 provides that remuneration from employment is taxable only in the recipient's resident State unless the employment is exercised in the other Contracting State, in which event that other State may tax the remuneration. A three-part exception preserves exclusive residence-state taxation where the recipient's presence in the other State does not exceed a specified presence threshold, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration of regular ship or aircraft crew on international traffic is taxable only in the resident State.
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