Income From Employment
(1) Subject to the provisions of Articles 15, 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting Party in respect of an employment shall be taxable only in that Party unless the employment is exercised in the other Contracting Party. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Party.
(2) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting Party in respect of an employment exercised in the other Contracting Party shall be taxable only in the first-mentioned Party if:
- (a) the recipient is present in the other Party for a period or periods not exceeding in the aggregate 183 days in any 12 month period commencing or ending in the taxable period concerned, and
- (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Party, and
- (c) the remuneration is not borne by a permanent establishment which the employer has in the other Party.
(3) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting Party shall be taxable only in that Party.