Dependent personal services: residence generally taxes employment income unless services are exercised abroad and conditions for exemption apply. Article 15 allocates taxing rights for employment income: residence generally taxes salaries of its residents unless the employment is exercised in the other Contracting State. If the employee is present only for a limited aggregate period, paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there, taxation remains in the state of residence. A proviso permits the other State to tax when the remuneration is deductible against the employer's technical service fees and the employer lacks a permanent establishment there; this taxation is subject to a capped tax on gross remuneration. Crew of international ships or aircraft are taxable only 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: residence generally taxes employment income unless services are exercised abroad and conditions for exemption apply.
Article 15 allocates taxing rights for employment income: residence generally taxes salaries of its residents unless the employment is exercised in the other Contracting State. If the employee is present only for a limited aggregate period, paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there, taxation remains in the state of residence. A proviso permits the other State to tax when the remuneration is deductible against the employer's technical service fees and the employer lacks a permanent establishment there; this taxation is subject to a capped tax on gross remuneration. Crew of international ships or aircraft are taxable only in the enterprise's state.
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