Dependent personal services: residence-based taxation applies unless employment is exercised abroad, subject to treaty exceptions. Remuneration from dependent personal services is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State. If the employment is exercised there, that State may tax the remuneration unless three conditions are met: the employee's presence in the other State does not exceed the applicable presence threshold in the relevant year, the payer is not a resident of the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that State. Employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.
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: residence-based taxation applies unless employment is exercised abroad, subject to treaty exceptions.
Remuneration from dependent personal services is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State. If the employment is exercised there, that State may tax the remuneration unless three conditions are met: the employee's presence in the other State does not exceed the applicable presence threshold in the relevant year, the payer is not a resident of the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that State. Employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.
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