Taxation of employment income: generally taxable in residence state unless employment exercised abroad; limited-presence exceptions apply. Salaries, wages and similar remuneration are generally taxable only in the state of residence unless the employment is exercised in the other Contracting State. Reciprocal exceptions prevent source-state taxation where the employee's presence is limited, the payor is not resident in the source state, the remuneration is taxed in the residence state, and the remuneration is not deductible for the source-state enterprise. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the state of the enterprise's place of effective management.
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: generally taxable in residence state unless employment exercised abroad; limited-presence exceptions apply.
Salaries, wages and similar remuneration are generally taxable only in the state of residence unless the employment is exercised in the other Contracting State. Reciprocal exceptions prevent source-state taxation where the employee's presence is limited, the payor is not resident in the source state, the remuneration is taxed in the residence state, and the remuneration is not deductible for the source-state enterprise. Remuneration for employment aboard ships or aircraft in international traffic may be taxed in the state of the enterprise's place of effective management.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
