Dependent Personal Services: taxation generally in resident state unless employment exercised abroad; limited exceptions allow source taxation.

Article 15 allocates primary taxation of employment remuneration to the employee's State of residence unless the employment is exercised in the other Contracting State, permitting source-state taxation where duties are performed there. A three-part exception preserves exclusive residence-state taxation where the employee's presence in the source State is limited, the payer is not resident in the source State, and the remuneration is not borne by a permanent establishment or fixed base of the employer. Remuneration for services aboard ships or aircraft in international traffic and compensation of nationals employed by enterprises principally operating aircraft are taxable only in the State of residence.

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