Dependent personal services: residence-based taxation with narrow short-term presence and employer-based exceptions. Article 15 allocates primary taxation of employment income to the employee's State of residence unless the employment is exercised in the other Contracting State. An exception limits the other State's taxing right when the presence in that State is short term, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of the enterprise's place of effective management.
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-based taxation with narrow short-term presence and employer-based exceptions.
Article 15 allocates primary taxation of employment income to the employee's State of residence unless the employment is exercised in the other Contracting State. An exception limits the other State's taxing right when the presence in that State is short term, the employer is not resident there, and the remuneration is not borne by a permanent establishment or fixed base of the employer. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of the enterprise's place of effective management.
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