Dependent personal services: employment income taxable in resident state unless exercised abroad, with limited short term and employer residence exceptions. Salaries, wages and similar remuneration paid to a resident are 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, exclusive taxation by the resident State applies where the employee's presence in the other State is limited to short term visits, the employer 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.
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: employment income taxable in resident state unless exercised abroad, with limited short term and employer residence exceptions.
Salaries, wages and similar remuneration paid to a resident are 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, exclusive taxation by the resident State applies where the employee's presence in the other State is limited to short term visits, the employer 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.
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