https://www.taxtmi.com/acts?id=5667 Article 15 allocates taxing rights for employment income: residence generally taxes salaries of its residents unless the employment is exercised in the other Contracting State. If the employee is present only for a limited aggregate period, paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there, taxation remains in the state of residence. A proviso permits the other State to tax when the remuneration is deductible against the employer's technical service fees and the employer lacks a permanent establishment there; this taxation is subject to a capped tax on gross remuneration. Crew of international ships or aircraft are taxable only in the enterprise's state. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 07 Oct 2024 16:36:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5667 Article 15 allocates taxing rights for employment income: residence generally taxes salaries of its residents unless the employment is exercised in the other Contracting State. If the employee is present only for a limited aggregate period, paid by an employer not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base there, taxation remains in the state of residence. A proviso permits the other State to tax when the remuneration is deductible against the employer's technical service fees and the employer lacks a permanent establishment there; this taxation is subject to a capped tax on gross remuneration. Crew of international ships or aircraft are taxable only in the enterprise's state. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5667