Dependent personal services: employment income generally taxable in resident state unless exercised abroad; limited exemptions permit source-state taxation.

Remuneration from employment is taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, whereupon that remuneration may be taxed in the State of exercise; however, source-state taxation is excluded if the presence in the other State is within the Convention's threshold, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment aboard ships or aircraft in international traffic is taxable only in the enterprise's State.

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