Taxation of employment income: residence-state taxation unless employment exercised in other state, limited exceptions apply. Salaries, wages and similar remuneration from employment are taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exemption applies where the employee's presence in the other State is limited, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there. Special rules address employment aboard internationally operated ships or aircraft and an exemption for nationals employed by a designated national air carrier.
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.
Taxation of employment income: residence-state taxation unless employment exercised in other state, limited exceptions apply.
Salaries, wages and similar remuneration from employment are taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. An exemption applies where the employee's presence in the other State is limited, the employer is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base there. Special rules address employment aboard internationally operated ships or aircraft and an exemption for nationals employed by a designated national air carrier.
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