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    <description>Remuneration derived by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax it. However, such remuneration is taxable only in the resident State if the employee&#039;s presence in the other State falls below the specified aggregate presence threshold for the relevant twelve-month periods, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment there. Wages of regular complement of ships or aircraft in international traffic remain taxable only in the State of residence.</description>
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      <description>Remuneration derived by a resident is taxable only in the State of residence unless the employment is exercised in the other State, in which case that other State may tax it. However, such remuneration is taxable only in the resident State if the employee&#039;s presence in the other State falls below the specified aggregate presence threshold for the relevant twelve-month periods, the payer is not resident in the other State, and the remuneration is not borne by a permanent establishment there. Wages of regular complement of ships or aircraft in international traffic remain taxable only in the State of residence.</description>
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