Dependent personal services: taxed in resident state unless exercised abroad; short-term presence and non-resident employer can limit taxation. Dependent personal services are taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. However, remuneration for employment exercised in the other State is taxable only in the residence State where the employee's presence abroad is limited to short-term aggregate periods, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there.