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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

Personal Services

(1) Subject to the provisions of Articles 16, 18, 19, 20 and 21 remuneration derived by an individual who is a resident of one of the States in respect of personal services, including professional services shall be taxable only in that State unless the services are performed in the other State. If the services are so performed, such remuneration as is derived in respect thereof may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a resident of one of the States in respect of personal services, including professional services performed in the other State shall be taxable only in the first-mentioned State if:

  • (a) the recipient is present in that other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned, and
  • (b) the remuneration is paid by, or on behalf of, a person who is not a resident of that other State, and
  • (c) the remuneration is not borne by a permanent establishment which the individual or his employer, as the case may be, has in that other State.

(3) The term "professional services" includes independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.

(4) Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of one of the States may be taxed in that State.