Dependent personal services taxation limited to residence unless employment exercised abroad; short-term presence and non-resident employer exceptions apply. Dependent personal services income paid to a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, taxation remains in the resident State where presence abroad is limited, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there.
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 taxation limited to residence unless employment exercised abroad; short-term presence and non-resident employer exceptions apply.
Dependent personal services income paid to a resident is taxable only in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration; however, taxation remains in the resident State where presence abroad is limited, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
