Dependent personal services: employment income taxed in residence unless source-state conditions permit taxation. Article 16 allocates primary taxation of salaries, wages and similar remuneration to the recipient's State of residence unless the employment is exercised in the other Contracting State. Remuneration for employment exercised in the other State is taxable there unless three cumulative conditions are satisfied: short-term presence of the recipient, payment by an employer not resident in the other State, and remuneration not borne by a permanent establishment or fixed base of the employer in that State. Remuneration aboard international ships or aircraft is taxable where the enterprise's place of effective management is situated.
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.
Dependent personal services: employment income taxed in residence unless source-state conditions permit taxation.
Article 16 allocates primary taxation of salaries, wages and similar remuneration to the recipient's State of residence unless the employment is exercised in the other Contracting State. Remuneration for employment exercised in the other State is taxable there unless three cumulative conditions are satisfied: short-term presence of the recipient, payment by an employer not resident in the other State, and remuneration not borne by a permanent establishment or fixed base of the employer in that State. Remuneration aboard international ships or aircraft is taxable where the enterprise's place of effective management is situated.
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