Dependent personal services: employment income taxed in resident state unless duties are performed abroad, subject to short term presence exceptions.

Article 14 treats dependent personal services remuneration as taxable in the employee's State of residence unless employment is exercised in the other Contracting State, in which case that other State may tax the income. An exception confines taxation to the residence State where the employee's presence in the other State is limited, the payer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that other State. Remuneration from employment aboard aircraft in international traffic is taxable only in the State of the enterprise operating the aircraft.

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