Residence-based taxation of employment income limited by presence, employer residence and permanent establishment conditions.

Dependent personal services income is taxable in the employee's State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. An exclusive residence taxation rule applies where presence in the other State is limited by a short-duration presence threshold, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Employment aboard ships or aircraft in international traffic may be taxed by the enterprise's State.

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