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    <title>Dependent personal services</title>
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      <description>Remuneration for dependent personal services is taxable in the recipient&#039;s State of residence unless the employment is exercised in the other State, in which case that other State may tax it. However, where three conditions are satisfied - short aggregate presence in the other State, payment by an employer not resident in that other State, and the remuneration not borne by a permanent establishment or fixed base there - taxation is confined to the residence State. Pay for employment on ships or aircraft in international traffic may be taxed by the State of the enterprise&#039;s residence.</description>
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