Dependent personal services: employment income taxable in residence state unless exercised abroad, subject to presence, employer residence and deductibility conditions.

Article 16 allocates taxation of employment remuneration: resident-derived salaries and similar pay are taxable only in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, the other State shall not tax the remuneration if three conditions are satisfied: the worker's presence in the other State does not exceed the prescribed presence threshold during the fiscal year; the remuneration is paid by or on behalf of an employer not resident in that other State; and the remuneration is not deductible against an enterprise's profits taxable in that other State. Employment aboard ships or aircraft in international traffic may be taxed in the State of residence of the enterprise operating the vessel.

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