Residence-based taxation of employment income limited by presence, employer residence, and permanent establishment conditions. Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. However, remuneration earned while performing duties in the other State is taxable only in the resident State if the recipient's presence there is limited, the employer is not resident in that State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that State. Remuneration for service aboard an enterprise's ship or aircraft in international traffic may be taxed by the State of the enterprise.
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.
Residence-based taxation of employment income limited by presence, employer residence, and permanent establishment conditions.
Salaries, wages and similar remuneration derived by a resident are taxable only in that State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. However, remuneration earned while performing duties in the other State is taxable only in the resident State if the recipient's presence there is limited, the employer is not resident in that State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in that State. Remuneration for service aboard an enterprise's ship or aircraft in international traffic may be taxed by the State of the enterprise.
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