Dependent personal services: employment income taxed in resident state unless exercised abroad, subject to employer and connection conditions. Salaries and similar remuneration are taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception bars taxation by the State where the employment is exercised if the stay is short, the employer is resident in the employee's State, and the remuneration is not connected with a permanent establishment there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the State of the enterprise.
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 taxed in resident state unless exercised abroad, subject to employer and connection conditions.
Salaries and similar remuneration are taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that State may tax such remuneration. An exception bars taxation by the State where the employment is exercised if the stay is short, the employer is resident in the employee's State, and the remuneration is not connected with a permanent establishment there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the State of the enterprise.
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