Employment income taxation allocates source-State taxing rights unless the employee meets temporary-presence, foreign-employer, and non-borne remuneration conditions.

Employment remuneration is taxable only in the employee's State of residence unless the employment is exercised in the other Contracting State, which may then tax the related remuneration. Exclusive residence-State taxation applies where temporary presence does not exceed the prescribed period, the employer is not resident in the other State, and remuneration is not borne by a permanent establishment or fixed base there. Employment aboard a ship or aircraft in international traffic is taxable only where the enterprise's place of effective management is situated.

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