Dependent personal services: taxable in resident state unless exercised abroad; exemption where presence below threshold and employer non-resident. Salaries, wages and similar remuneration of a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case such remuneration may be taxed there. Remuneration exercised in the other State is taxable only in the resident State if: the recipient's presence in the other State does not exceed the aggregate presence threshold for the year; the payment is made by an employer who is not resident in the other State; and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration aboard ships or aircraft in international traffic may be taxed 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: taxable in resident state unless exercised abroad; exemption where presence below threshold and employer non-resident.
Salaries, wages and similar remuneration of a resident are taxable only in that State unless the employment is exercised in the other Contracting State, in which case such remuneration may be taxed there. Remuneration exercised in the other State is taxable only in the resident State if: the recipient's presence in the other State does not exceed the aggregate presence threshold for the year; the payment is made by an employer who is not resident in the other State; and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration aboard ships or aircraft in international traffic may be taxed in the enterprise's State.
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