https://www.taxtmi.com/acts?id=15035 Article 15 provides that remuneration for dependent personal services is taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax it. An exception prevents source-state taxation where three cumulative conditions are met: the worker's presence in the source State is below the treaty's aggregate presence threshold in the relevant twelve month period, the payor is not a resident of the source State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the source State. Remuneration aboard ships or aircraft in international traffic may be taxed by the enterprise's State of residence. en-us Tue, 30 Aug 2011 13:07:24 +0530 Tue, 26 Nov 2024 17:32:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15035 Article 15 provides that remuneration for dependent personal services is taxable only in the resident State unless the employment is exercised in the other State, in which case that other State may tax it. An exception prevents source-state taxation where three cumulative conditions are met: the worker's presence in the source State is below the treaty's aggregate presence threshold in the relevant twelve month period, the payor is not a resident of the source State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the source State. Remuneration aboard ships or aircraft in international traffic may be taxed by the enterprise's State of residence. Act-Rules DTAA Tue, 30 Aug 2011 13:07:24 +0530 https://www.taxtmi.com/acts?id=15035