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    <description>Remuneration for employment is taxable in the State of residence unless the employment is exercised in the other Contracting State, in which case that other State may tax such remuneration. However, employment income exercised in the other State is taxable only in the resident State if the worker&#039;s presence in the other State falls below a limited presence threshold for the fiscal year, the payor is not resident in the other State, and the pay is not borne by a permanent establishment or fixed base there. Income from employment aboard ships or aircraft in international traffic may be taxed where the enterprise&#039;s place of effective management is located.</description>
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