Taxation of employment income: residency-based tax applies unless work is exercised abroad, with presence, employer residence and permanent establishment exceptions. Dependent personal services income is normally taxable only in the individual's State of residence unless the employment is exercised in the other State. A three-part exception preserves exclusive taxation by the resident State where visits to the other State are limited, the employer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's 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: residency-based tax applies unless work is exercised abroad, with presence, employer residence and permanent establishment exceptions.
Dependent personal services income is normally taxable only in the individual's State of residence unless the employment is exercised in the other State. A three-part exception preserves exclusive taxation by the resident State where visits to the other State are limited, the employer is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.
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