Employment income was traditionally styled in treaties as ‘dependent personal services’. This is now simply referred to as ‘Income from employment’ in the OECD Model, to make the heading more consistent with the type of activities to which the article relates, and modern UK treaties conform with this language.

The general approach is that residents are normally liable to tax on employment income in their country of residence only, unless the employment is exercised in the other contracting state. The OECD rule is reflected in art. 15(1) of the Hungary-UK double tax treaty (1977) as follows:

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