Dependent personal services: taxable in the resident state unless exercised abroad, with limited exceptions. Dependent personal services allocate taxing rights to the State of residence unless the employment is exercised in the other Contracting State. Remuneration exercised in the other State may be taxed there, except where presence in the other State falls below a specified aggregate threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base; remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of the 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: taxable in the resident state unless exercised abroad, with limited exceptions.
Dependent personal services allocate taxing rights to the State of residence unless the employment is exercised in the other Contracting State. Remuneration exercised in the other State may be taxed there, except where presence in the other State falls below a specified aggregate threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base; remuneration for employment aboard ships or aircraft in international traffic is taxable only in the State of the place of effective management.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
