Dependent personal services taxation: residence generally governs, with short term presence and employer residence exceptions affecting source taxation. Salaries, wages and similar remuneration from dependent personal services are taxable only in the resident State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. A limitation prevents source state taxation if the worker's presence in the source State is limited to a short term, remuneration is paid by or on behalf of a non resident employer, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that State; employment aboard ships or aircraft in international traffic may be taxed in the employer's State.
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Provisions expressly mentioned in the judgment/order text.
Dependent personal services taxation: residence generally governs, with short term presence and employer residence exceptions affecting source taxation.
Salaries, wages and similar remuneration from dependent personal services are taxable only in the resident State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. A limitation prevents source state taxation if the worker's presence in the source State is limited to a short term, remuneration is paid by or on behalf of a non resident employer, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that State; employment aboard ships or aircraft in international traffic may be taxed in the employer's State.
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