Taxation of employment income: residence-state taxation unless work is exercised abroad; short-term presence and non-resident employer limit source taxing rights. Salaries, wages and similar remuneration of a resident are taxable only in the residence State unless the employment is exercised in the other Contracting State, where that State may tax the remuneration. However, where the employment is exercised in the other State only for a limited duration, the pay is made by a non-resident employer and is not borne by a permanent establishment or fixed base in the other State, taxation remains with the residence State. Remuneration for service aboard a ship or aircraft in international traffic is taxable in the State of the operating 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.
Taxation of employment income: residence-state taxation unless work is exercised abroad; short-term presence and non-resident employer limit source taxing rights.
Salaries, wages and similar remuneration of a resident are taxable only in the residence State unless the employment is exercised in the other Contracting State, where that State may tax the remuneration. However, where the employment is exercised in the other State only for a limited duration, the pay is made by a non-resident employer and is not borne by a permanent establishment or fixed base in the other State, taxation remains with the residence State. Remuneration for service aboard a ship or aircraft in international traffic is taxable in the State of the operating enterprise.
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