Dependent personal services: residence taxation normally applies unless exercise abroad meets presence, employer residence, and PE conditions.

Remuneration for employment is taxable only in the resident State unless the employment is exercised in the other Contracting State, which may then tax it; however, exclusive residence-state taxation applies where presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by the employer's permanent establishment or fixed base in that other State. Remuneration for employment aboard international ships, aircraft, or inland-waterway boats may be taxed in the State of residence of the operating enterprise.

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