Dependent personal services taxation: residency-based tax with short term presence exception and employer/payment conditions limiting source taxation.

Dependent personal services income is taxable in the resident Contracting State unless the employment is exercised in the other State, where it may be taxed. However, a short term presence exception provides that such remuneration is taxable only in the State of residence if the recipient's aggregate presence in the other State does not exceed the applicable short term threshold, 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 there.

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