Dependent personal services

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....racting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. ^1[2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: a) the recipient is present....

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.... taxable only in the first-mentioned State.]     *************** NOTES:- 1.  Substituted vide Notification No. 39/2026 dated 30-03-2026 before it was read as, "2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable....