Dependent personal services: employment income generally taxed in residence state unless exercised abroad; short term presence exception limits taxation. Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State, where such remuneration may be taxed; however, remuneration for employment exercised in the other State is taxable only in the State of residence if the recipient's presence in the other State is short-term, the remuneration is paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that 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.
Dependent personal services: employment income generally taxed in residence state unless exercised abroad; short term presence exception limits taxation.
Salaries, wages and similar remuneration of a resident are taxable only in the State of residence unless the employment is exercised in the other Contracting State, where such remuneration may be taxed; however, remuneration for employment exercised in the other State is taxable only in the State of residence if the recipient's presence in the other State is short-term, the remuneration is paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State.
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