Dependent personal services taxation: limited-source taxation when presence, employer residence and permanent establishment conditions are met.

Salaries, wages and similar remuneration of a resident are taxable only in the resident State unless the employment is exercised in the other Contracting State; however, where the employee is present in the other State only for a limited aggregate period, the payor is not resident in that other State, and the remuneration is not borne by a permanent establishment or fixed base or trade or business of the employer there, taxation remains with the resident State. Remuneration for service on a ship or aircraft in international traffic may be taxed by the Contracting State of the enterprise.

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