Dependent personal services: residency-based taxation with short-term cross-border exception where non-resident employer pays and no PE bears costs.

Remuneration from employment is taxable in the employee's State of residence unless the employment is exercised in the other State, in which case that other State may tax the remuneration; however, where the employment is exercised in the other State on a short term basis and the payor is not resident in that other State and the remuneration is not borne by the employer's permanent establishment or fixed base there, taxation remains with the State of residence. Remuneration for service aboard ships or aircraft in international traffic may be taxed where the enterprise's registered office is situated.

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