Dependent personal services: employment income generally taxed in residence, with limited exceptions for service location and employer ties.

Salaries, wages and similar remuneration derived by a resident of one Contracting State are taxable only in that State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. Remuneration earned in the other State is taxable only in the resident State if the individual's presence in the other State is limited, the payor is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there. Remuneration for employment on ships or aircraft in international traffic may be taxed in the operating State.

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