Dependent personal services: employment income taxable in resident state unless exercised abroad; short-term presence exceptions apply.

Remuneration from employment is taxable only in the recipient's State of residence unless the employment is exercised in the other Contracting State, where it may be taxed. However, such remuneration is taxable only in the State of residence if three conditions are met: the recipient's presence in the other State is of limited aggregate duration, the payer 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 may be taxed in the enterprise's State.

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