OECD proposes that non-compete payments be taxable only in the country of residence of the recipient

An OECD Working Group has released a draft proposal to add commentary on the treatment of payments received by an employee following cessation of employment.  For example, they suggest that severance payments be treated as remuneration derived from the State where the employment was exercised when the employment was terminated, and that non-compete payments generally be treated as taxable only in the State where the recipient resides during the period covered by the payments.

Neal Armstrong.  Summary of OECD Discussion Draft, Working Party 1 "OECD Model Tax Convention: Tax Treatment of Termination Payments" under Treaties – Art. 15.