Taxation of employment income: residence state generally taxed unless employment exercised abroad; short-term presence exceptions apply. Remuneration of a resident for employment is taxable only in the residence state unless the employment is exercised in the other Contracting State; however, where the employee's presence in the other State is limited to a short aggregate period, the payor is not resident in the other State, and the remuneration is not borne by an enterprise, permanent establishment or fixed base there, the remuneration is taxable only in the residence state. Remuneration for employment aboard a ship or aircraft in international traffic by an enterprise of a Contracting State is taxable only in that 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.
Taxation of employment income: residence state generally taxed unless employment exercised abroad; short-term presence exceptions apply.
Remuneration of a resident for employment is taxable only in the residence state unless the employment is exercised in the other Contracting State; however, where the employee's presence in the other State is limited to a short aggregate period, the payor is not resident in the other State, and the remuneration is not borne by an enterprise, permanent establishment or fixed base there, the remuneration is taxable only in the residence state. Remuneration for employment aboard a ship or aircraft in international traffic by an enterprise of a Contracting State is taxable only in that State.
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