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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 15

Dependent Personal Services

(1) Subject to the provisions of Articles 16, 17, 18, 19, 20 and 21 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived there from may be taxed in that other Contracting State.

(2) Notwithstanding the provisions of paragraph (1) of this Article 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 Contracting State if:

  • (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and
  • (b) the remuneration is paid by, or on behalf of, an employer, who is not a resident of the other Contracting State, and
  • (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State.

(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 shall be taxable in the Contracting State of which the enterprise operating ship or aircraft is a resident.

(4) Notwithstanding the provisions of paragraphs (1) and (2) of this Article remuneration of the ground staff of an air company of a Contracting State who are nationals of that State and who provide services connected with aircraft operation in the other Contracting State shall be taxable only in the first-mentioned Contracting State.