https://www.taxtmi.com/caselaws?id=800087 Salary earned by a Vietnam tax resident for employment exercised wholly in Vietnam accrued where the services were performed and was taxable in Vietnam. Under the India-Vietnam DTAA, read with section 90, employment remuneration is governed by the treaty residence and employment provisions. Sections 5(2), 9(1) and 15(1)(a) treat the place of performance as determinative of salary accrual. Payment through an Indian payroll, credit to an Indian bank account, and Indian tax withholding do not by themselves make that foreign employment income taxable in India. en-us Mon, 27 Jul 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800087 Salary earned by a Vietnam tax resident for employment exercised wholly in Vietnam accrued where the services were performed and was taxable in Vietnam. Under the India-Vietnam DTAA, read with section 90, employment remuneration is governed by the treaty residence and employment provisions. Sections 5(2), 9(1) and 15(1)(a) treat the place of performance as determinative of salary accrual. Payment through an Indian payroll, credit to an Indian bank account, and Indian tax withholding do not by themselves make that foreign employment income taxable in India. Case-Laws Income Tax Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800087