Taxation of employment income: residency allocates primary taxing right, with source taxation limited by presence, employer residence, and PE attribution. Remuneration from employment 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 it. However, remuneration remains taxable only in the State of residence if the employee's presence in the other State is limited, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Wages for service aboard ships or aircraft in international traffic are taxable only in the enterprise's State of residence.
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: residency allocates primary taxing right, with source taxation limited by presence, employer residence, and PE attribution.
Remuneration from employment 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 it. However, remuneration remains taxable only in the State of residence if the employee's presence in the other State is limited, the employer is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Wages for service aboard ships or aircraft in international traffic are taxable only in the enterprise's State of residence.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
