Dependent personal services: allocation of taxing rights on employment income with a temporary presence exception. Remuneration for employment is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration. An exclusive-residence exception applies when the employee's presence in the source State is temporary under a presence threshold, the employer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of residence.
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: allocation of taxing rights on employment income with a temporary presence exception.
Remuneration for employment is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax such remuneration. An exclusive-residence exception applies when the employee's presence in the source State is temporary under a presence threshold, the employer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of residence.
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