Dependent Personal Services
(1) Without prejudice to the provisions of Articles 15, 17 and 18 hereof, salaries, wages and other similar remuneration taken by a resident of a Contracting State-for an employment-shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration shall be taxed in that other Contracting State.
(2) Notwithstanding the provisions of abovementioned paragraph (1), remunerations gained by a resident in 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 beneficiary is resident in the other Contracting State for a period or periods not exceeding (183) days in aggregate within a period of 12 months that starts or ends in the relevant taxable year.
- (b) The remuneration is paid by, or on behalf of, an employer which is not a resident in the other Contracting State.
- (c) The remuneration is not incurred by a permanent establishment or a fixed base the employer owns in other Contracting State.
(3) Notwithstanding the provisions stipulated hereof, remuneration gained by a resident in a Contracting State through an employment he/she exercises aboard a ship or aircraft operated in international transport may be taxed in the Contracting State where the actual headquarters of the enterprise management is situated.