Dependent Personal Services: employment income taxed in resident state unless exercised abroad, subject to a short term presence exception. Salaries, wages and similar remuneration are taxable in the earner's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, exclusive taxation by the resident State applies where short-term presence, non resident employer payment, and absence of employer permanent establishment conditions are all satisfied, and remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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Provisions expressly mentioned in the judgment/order text.
Dependent Personal Services: employment income taxed in resident state unless exercised abroad, subject to a short term presence exception.
Salaries, wages and similar remuneration are taxable in the earner's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, exclusive taxation by the resident State applies where short-term presence, non resident employer payment, and absence of employer permanent establishment conditions are all satisfied, and remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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